Martin Ice Cream Company v. Commissioner

110 T.C. No. 18

UNITED STATES TAX COURT MARTIN ICE CREAM COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1477-93. Filed March 17, 1998. A and his son M were shareholders of MIC, an S corporation that distributed ice cream products to supermarket chains, independent grocery stores, and food service accounts. MIC's supermarket business was largely attributable to the close personal relation- ships that A had developed and maintained for decades, beginning before the creation of MIC in 1971, with the owners and managers of the supermarket chains. Since 1974, MIC had…