Electric Regulator Corporation v. Commissioner of Internal Revenue

MOORE, Circuit Judge:

Electric Regulator Corporation (petitioner) petitions for a review of a decision of the Tax Court of the United States, 40 T.C. 757 (1963), sustaining the Commissioner’s determination of deficiencies in income tax for its fiscal years 1957 and 1958 in the amounts of $81,751.-01 and $25,944.69. These deficiencies resulted from the Commissioner’s imposition of an accumulated earnings tax pursuant to Internal Revenue Code of 1954, § 531 1 for each of the years in question. The Tax Court found that petitioner permitted its earnings and profits to accumulate beyond the reason…