I. A. Dress Co. v. Commissioner
United States Tax Court
Petitioner accumulated earnings and profits beyond the reasonable needs of its business in 1949 and was availed of for the purpose of preventing the imposition of surtax upon its sole stockholder within the meaning of section 102, I.R.C. 1939.
1Opinion of the Court
Withex, Judge:
Eespondent determined a deficiency in petitioner’s income tax for 1949 in the amount of $6,609.78.
The issue presented for our decision is the correctness of the respondent’s action in determining that petitioner was availed of during 1949 for the purpose of avoiding the imposition of surtax upon its shareholder within the meaning of section 102 of the Internal Eevenue Code of 1939.
FINDINGS OF FACT.
Some of the facts have been stipulated and are found accordingly.
Petitioner is a corporation organized on October 18,1924, under the laws of the State of New York and at all times here…
2Cases cited10 opinions
- Pelton Steel Casting Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958
- Pelton Steel Casting Co. v. CommissionerUnited States Tax Court · 1957
- Dixie, Inc. v. CommissionerUnited States Tax Court · 1958
- Kerr-Cochran, Inc. v. CommissionerUnited States Tax Court · 1958
- Kerr-Cochran, Incorporated, a Nebraska Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1958
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3Cited by47 opinions
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- American Metal Products Corp. v. CommissionerUnited States Tax Court · 1960
- Gilberg v. CommissionerUnited States Tax Court · 1971
- J. Gordon Turnbull, Inc. v. CommissionerUnited States Tax Court · 1963
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