Alex Brown, Inc. v. Commissioner
United States Tax Court
In late December 1968, petitioner sold its operating assets. Between that time and the end of its current fiscal year on May 31, 1969, it made no plans for any further business activities. Its assets were invested in cash and marketable securities.
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In late December 1968, petitioner sold its operating assets. Between that time and the end of its current fiscal year on May 31, 1969, it made no plans for any further business activities. Its assets were invested in cash and marketable securities. Held, petitioner became a "mere holding or investment company" (see sec. 533(b), I.R.C. 1954). Further held, petitioner was formed or availed of for the purpose of avoiding income tax with respect to its shareholders and is therefore subject to the accumulated-earnings tax for such fiscal year.
1Opinion of the Court
Alex Brown, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Alex Brown, Inc. v. Commissioner
Docket No. 1162-72
United States Tax Court
60 T.C. 364; 1973 U.S. Tax Ct. LEXIS 112; 60 T.C. No. 43;
June 11, 1973, Filed
Decision will be entered for the respondent.
In late December 1968, petitioner sold its operating assets. Between that time and the end of its current fiscal year on May 31, 1969, it made no plans for any further business activities. Its assets were invested in cash and marketable securities. Held, petitioner became a "mere holding or investment company" (see sec. 533(b),…
2Cases cited12 opinions
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- Dixie, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
- Bremerton Sun Publishing Co. v. CommissionerUnited States Tax Court · 1965
- Dixie, Inc. v. CommissionerUnited States Tax Court · 1958
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