Metro Leasing & Dev. Corp. v. Comm'r
United States Tax Court
In an earlier opinion, we decided that P permitted its 1995 earnings to accumulate beyond the reasonable needs of its business. Secs. 531- 537, I.R.C. There remains, however, a dispute concerning the computation of the accumulated earnings tax.
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In an earlier opinion, we decided that P permitted its 1995 earnings to accumulate beyond the reasonable needs of its business. Secs. 531- 537, I.R.C. There remains, however, a dispute concerning the computation of the accumulated earnings tax. P contends, alternatively, that R failed to reduce P's accumulated earnings tax base by the following amounts: (1) "Deferred" tax attributable to installment sale proceeds to be received by P in tax years after 1995; (2) the amount of the income tax deficiency determined by respondent which remains contested by P and for which P has made payment after…
1Opinion of the Court
SUPPLEMENTAL OPINION1
Gerber, Judge:
In an earlier opinion, we decided that petitioner permitted its 1995 earnings to accumulate beyond the reasonable needs of its business. See secs. 531-537;2 Metro Leasing & Dev. Corp. v. Commissioner, T.C. Memo. 2001-119. We also decided the amount of reasonable compensation" for petitioner’s officers. To reflect our holding and to adjust for agreed items, the parties were required to compute the amount of resulting income tax and accumulated earnings tax liabilities pursuant to Rule 155 computation procedures.
The parties, in docket No. 8054-99, disagree…
2Cases cited14 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Ivan Allen Co. v. United StatesSupreme Court of the United States · 1975
- Estate of Goodall v. CommissionerCourt of Appeals for the Eighth Circuit · 1968
- J.H. Rutter Rex Mfg. Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
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3Cited by5 opinions
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- Metro Leasing and Development Corporation, East Bay Chevrolet Company, a Corporation v. CommissionerUnited States Tax Court · 2002