Legal Opinion

John P. Scripps Newspapers v. Commissioner

United States Tax Court

Decided June 25, 1965No. Docket No. 4672-62PublishedCited by 73 opinions

Held, the accumulation of petitioner's surplus during the years in issue was not beyond the reasonable needs of its business. Held, further, in view of the above holding and the operation of section 535(c)(1), I.R.C. 1954, it is not necessary to determine whether petitioner was availed of for the proscribed purpose contained in section 532(a), I.R.C. 1954.

1Opinion of the Court

Fay, Judge:

The respondent determined deficiencies in petitioner’s income tax as follows:

Taxable year Deficiency

1957_ $21,458. 54

1958_ 23,226. 85

1959 — . 32, 964. 51

The only issue for decision is whether petitioner is subject to tax under section 5311 with respect to all or any part of the earnings retained by it in any of the years involved herein.

FINDINGS OF FACT

Some of the facts have been stipulated, and the stipulation of facts, together with the exhibits attached thereto, is incorporated herein by this reference.

Petitioner is a corporation with principal place of business -and office…

2Cases cited26 opinions

  1. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  2. The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
  3. Dixie, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
  4. The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
  5. Dixie, Inc. v. CommissionerUnited States Tax Court · 1958

21 more not listed; retrieve them via the Exa API.

3Cited by73 opinions

  1. Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
  2. Ivan Allen Co. v. United StatesSupreme Court of the United States · 1975
  3. Bremerton Sun Publishing Co. v. CommissionerUnited States Tax Court · 1965
  4. Magic Mart, Inc. v. CommissionerUnited States Tax Court · 1969
  5. Rutter v. CommissionerUnited States Tax Court · 1983

68 more not listed; retrieve them via the Exa API.

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