Legal Opinion

Myco Industries, Inc. v. Commissioner

United States Tax Court

Decided March 12, 1992No. Docket No. 6195-91Unpublished

1Opinion of the Court

MYCO INDUSTRIES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Myco Industries, Inc. v. Commissioner

Docket No. 6195-91

United States Tax Court

T.C. Memo 1992-147; 1992 Tax Ct. Memo LEXIS 155; 63 T.C.M. (CCH) 2355; T.C.M. (RIA) 92147;

March 12, 1992, Filed

Karl Norman Clifford and Stephen J. Stone, for petitioner.

Martin M. Van Brauman, for respondent.

BEGHE

BEGHE

MEMORANDUM OPINION

BEGHE, Judge: This opinion addresses respondent's motion under Rule 142(e)1 to allocate the burden of proof on the reasonableness of petitioner's alleged business needs for accumulated earnings tax…

2Cases cited8 opinions

  1. Rutter v. CommissionerUnited States Tax Court · 1983
  2. Chatham Corp. v. CommissionerUnited States Tax Court · 1967
  3. Motor Fuel Carriers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1977
  4. J.H. Rutter Rex Mfg. Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
  5. Hughes, Inc. v. CommissionerUnited States Tax Court · 1988

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