Metro Leasing and Development Corporation, East Bay Chevrolet Company, a Corporation v. Commissioner

119 T.C. No. 2

UNITED STATES TAX COURT METRO LEASING AND DEVELOPMENT CORPORATION, EAST BAY CHEVROLET COMPANY, A CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket Nos. 8054-99. Filed July 17, 2002. In an earlier opinion, we decided that P permitted its 1995 earnings to accumulate beyond the reasonable needs of its business. Secs. 531-537, I.R.C. There remains, however, a dispute concerning the computation of the accumulated earnings tax. P contends, alternatively, that R failed to reduce P’s accumulated earnings tax base by the following amounts: (1) “Deferred” tax…