Pelton Steel Casting Co. v. Commissioner
United States Tax Court
Petitioner failed to divide and distribute accumulated earnings or profits during a taxable year when, as the record shows, such an accumulation was not reasonably necessary to meet any threat of unrest amongst its own employees, significant fluctuation in the level of its production or operating profits, or reasonably anticipated additions or improvements to its plant and equipment.
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Petitioner failed to divide and distribute accumulated earnings or profits during a taxable year when, as the record shows, such an accumulation was not reasonably necessary to meet any threat of unrest amongst its own employees, significant fluctuation in the level of its production or operating profits, or reasonably anticipated additions or improvements to its plant and equipment. The failure to so divide its earnings and profits was pursuant to a plan developed by its minority shareholder (20 per cent) by which petitioner would use the accumulated funds, as well as additional borrowed…
1Opinion of the Court
Pelton Steel Casting Co., Petitioner, v. Commissioner of Internal Revenue, Respondent
Pelton Steel Casting Co. v. Commissioner
Docket No. 50455
United States Tax Court
28 T.C. 153; 1957 U.S. Tax Ct. LEXIS 209;
April 25, 1957, Filed
Decision will be entered under Rule 50.
Petitioner failed to divide and distribute accumulated earnings or profits during a taxable year when, as the record shows, such an accumulation was not reasonably necessary to meet any threat of unrest amongst its own employees, significant fluctuation in the level of its production or operating profits, or reasonably anticipated…
2Cases cited23 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Helvering v. Chicago Stock Yards Co.Supreme Court of the United States · 1943
- United Business Corporation v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1933
- Pelton Steel Casting Co. v. CommissionerUnited States Tax Court · 1957
- J. L. Goodman Furniture Co. v. CommissionerUnited States Tax Court · 1948
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