J. Gordon Turnbull, Inc. v. Commissioner
United States Tax Court
Where petitioner accumulated earnings substantially in excess of its working capital requirements; where it was not necessary for petitioner to retain its earnings to meet any contingent liability it might have had on certain tort suits because there was virtually no possibility of liability with respect thereto; and where petitioner made large investments of funds in property unrelated to its architectural and engineering services business.
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Where petitioner accumulated earnings substantially in excess of its working capital requirements; where it was not necessary for petitioner to retain its earnings to meet any contingent liability it might have had on certain tort suits because there was virtually no possibility of liability with respect thereto; and where petitioner made large investments of funds in property unrelated to its architectural and engineering services business. Held, that under section 102, I.R.C. 1939, petitioner was availed of during the taxable years involved for the purpose of preventing imposition of surtax…
1Opinion of the Court
J. Gordon Turnbull, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
J. Gordon Turnbull, Inc. v. Commissioner
Docket No. 88456
United States Tax Court
41 T.C. 358; 1963 U.S. Tax Ct. LEXIS 5;
December 12, 1963
Decision will be entered under Rule 50.
Where petitioner accumulated earnings substantially in excess of its working capital requirements; where it was not necessary for petitioner to retain its earnings to meet any contingent liability it might have had on certain tort suits because there was virtually no possibility of liability with respect thereto; and where petitioner made…
2Cases cited25 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Pelton Steel Casting Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958
- American Metal Products Corporation v. Commissioner of Internal Revenue, Adler Metal Products Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
- Barrow Manufacturing Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
- American Metal Products Corp. v. CommissionerUnited States Tax Court · 1960
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