Legal Opinion
Yates Petroleum Corp. v. Commissioner
United States Tax Court
Decided March 12, 1992No. Docket No. 2729-91Unpublished
1Opinion of the Court
YATES PETROLEUM CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Yates Petroleum Corp. v. Commissioner
Docket No. 2729-91
United States Tax Court
T.C. Memo 1992-146; 1992 Tax Ct. Memo LEXIS 156; 63 T.C.M. (CCH) 2347; T.C.M. (RIA) 92146;
March 12, 1992, Filed
Karl Norman Clifford and Stephen J. Stone, for petitioner.
Martin M. Van Brauman, for respondent.
BEGHE
BEGHE
MEMORANDUM OPINION
BEGHE, Judge: This opinion addresses respondent's motion under Rule 142(e)1 to allocate the burden of proof on the reasonableness of petitioner's alleged business needs for accumulated earnings tax…
2Cases cited8 opinions
- Rutter v. CommissionerUnited States Tax Court · 1983
- Chatham Corp. v. CommissionerUnited States Tax Court · 1967
- Motor Fuel Carriers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1977
- J.H. Rutter Rex Mfg. Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Hughes, Inc. v. CommissionerUnited States Tax Court · 1988
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