Whitney Chain & Mfg. Co. v. Commissioner of Internal Revenue

This is an appeal from a decision of the Tax Court sustaining the respondent’s determination that for the year 1939 the petitioner was subject to the tax liability imposed by section 102 of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 102. The Tax Court made detailed findings of fact from which it concluded that during the taxable year the taxpayer’s earnings or profits were permitted to accumulate beyond the reasonable needs of its business instead of being distributed, and through such medium it was availed of for the purpose of preventing the imposition of surtaxes upon its…