Trico Products Corp. v. Com'r of Internal Revenue

CHASE, Circuit Judge.

This petition to review a decision of the Tax Court of the United States redetermining the surtaxes of the petitioner under § 102 of the Revenue Act of 1934? 26 U.S.C. A. Int.Rev.Acts, page 690, for the years 1934 and 1935, puts in issue whether or not there was substantial evidence to support the conclusion that the petitioner was “availed of for the purpose of preventing the imposition of the surtax upon its shareholders * * * through the medium of permitting gains and profits to accumulate instead of being divided or distributed. ijc Jji

The petitioner is a New York…