Magic Mart, Inc. v. Commissioner
United States Tax Court
Held, petitioner's earnings and profits for the taxable years 1959 through 1962 were not permitted to accumulate beyond the reasonable needs of petitioner's business including the reasonably anticipated needs of the business.
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Held, petitioner's earnings and profits for the taxable years 1959 through 1962 were not permitted to accumulate beyond the reasonable needs of petitioner's business including the reasonably anticipated needs of the business. Held, further, in view of the credit provided for in sec. 535 (c)(1) of the 1954 Code, it is unnecessary to consider whether petitioner was availed of for the proscribed purpose and, therefore, petitioner is not liable for the accumulated earnings tax imposed by sec. 531 of the 1954 Code. See secs. 531 through 537.
1Opinion of the Court
Magic Mart, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Magic Mart, Inc. v. Commissioner
Docket No. 6512-66
United States Tax Court
51 T.C. 775; 1969 U.S. Tax Ct. LEXIS 192;
February 17, 1969, Filed
Decision will be entered for the petitioner.
Held, petitioner's earnings and profits for the taxable years 1959 through 1962 were not permitted to accumulate beyond the reasonable needs of petitioner's business including the reasonably anticipated needs of the business. Held, further, in view of the credit provided for in sec. 535 (c)(1) of the 1954 Code, it is unnecessary to…
2Cases cited24 opinions
- United States v. Donruss Co.Supreme Court of the United States · 1969
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Dixie, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
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