Chatham Corp. v. Commissioner
United States Tax Court
Petitioner filed a pretrial motion requesting the Court to find that its timely statement purporting to comply with the requirements of sec. 534, I.R.C. 1954, was sufficient to place the burden of proof on respondent with respect to the grounds stated therein. Held, motion granted.
1Opinion of the Court
OPINION
Tannenwald, Judge:
This case involves a determination by respondent that petitioner is subject to the accumulated earnings tax under section 5311 for the fiscal years ending June 30,1961,1962,1963, and 1964. Respondent sent a notice to petitioner in accordance with section 534(b) and petitioner submitted a timely statement purporting to comply with, tlie requirements of section 534(c). At tbe call of tbe case for trial on February 17,1967, petitioner moved for a ruling tbat tbe burden of proof with respect to tbe grounds set forth in its statement rests upon respondent as provided in…
2Cases cited10 opinions
- Dixie, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- John P. Scripps Newspapers v. CommissionerUnited States Tax Court · 1965
- Dixie, Inc. v. CommissionerUnited States Tax Court · 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
- American Metal Products Corp. v. CommissionerUnited States Tax Court · 1960
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3Cited by24 opinions
- Dielectric Materials Co. v. CommissionerUnited States Tax Court · 1972
- Rutter v. CommissionerUnited States Tax Court · 1983
- Atlantic Properties, Inc. v. CommissionerUnited States Tax Court · 1974
- Hughes, Inc. v. CommissionerUnited States Tax Court · 1988
- Michael Di Peppino, Inc. v. CommissionerUnited States Tax Court · 1984
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