Snow Mfg. Co. v. Commissioner
United States Tax Court
P, a wholly owned subsidiary of a closely held corporation, remanufactured automobile parts. R determined that P was subject to the accumulated earnings tax for its taxable years ended June 30, 1979, and June 30, 1980. The parties disagreed as to whether P's reasonable business needs for fiscal 1979 and 1980 included the need to accumulate funds for expansion or relocation of its plant.
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P, a wholly owned subsidiary of a closely held corporation, remanufactured automobile parts. R determined that P was subject to the accumulated earnings tax for its taxable years ended June 30, 1979, and June 30, 1980. The parties disagreed as to whether P's reasonable business needs for fiscal 1979 and 1980 included the need to accumulate funds for expansion or relocation of its plant. The parties also disagreed about computation of the credit cycle in connection with the working capital analysis of Bardahl v. Commissioner, T.C. Memo. 1965-200. The parties further disagreed as to whether…
1Opinion of the Court
GERBER Judge:
Respondent determined deficiencies in petitioner’s income tax for petitioner’s taxable years ended June 30, 1979, and June 30, 1980, in the respective amounts of $109,816 and $70,968. After concessions, the issue before us is whether petitioner is liable for the accumulated earnings tax imposed by section 531.1
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly. The stipulation of facts and attached exhibits are incorporated herein by this reference.
Background
Petitioner, a California corporation, was incorporated in 1959 and was dissolved and…
2Cases cited27 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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3Cited by13 opinions
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- Technalysis Corp. v. CommissionerUnited States Tax Court · 1993
- Hoyle v. CommissionerUnited States Tax Court · 1994
- CF Indus., Inc. v. CommissionerUnited States Tax Court · 1991
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