Sandy Estate Co. v. Commissioner
United States Tax Court
Held, petitioner was not availed of during the taxable years for the purpose of avoiding the income tax in respect of its shareholders by permitting earnings and profits to accumulate instead of being divided or distributed. Sec. 532(a), I.R.C. 1954.
1Opinion of the Court
The Commissioner determined deficiencies in tax against petitioner as follows:
Fiscal year ended March 31-
Income tax
Accumulated earnings (sec. 531) tax
1958-$624.00 $30,328.13
1959. 8,584.54 28,431.80
1960. 4,987.71 35,491.06
The only matter presently in issue is whether petitioner was availed of during the foregoing tax years for the purpose of avoiding the income tax in respect of its sole stockholder by permitting earnings and profits to accumulate instead of being divided or distributed. The correctness of other adjustments has not been presented for decision.
FINDINGS OF FACT
A stipulation of…
2Cases cited18 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Pelton Steel Casting Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958
- Pelton Steel Casting Co. v. CommissionerUnited States Tax Court · 1957
- J. L. Goodman Furniture Co. v. CommissionerUnited States Tax Court · 1948
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3Cited by17 opinions
- John P. Scripps Newspapers v. CommissionerUnited States Tax Court · 1965
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- Bardahl Mfg. Corp. v. CommissionerUnited States Tax Court · 1965
- Alma Piston Co. v. CommissionerUnited States Tax Court · 1976
- Proctor v. CommissionerUnited States Tax Court · 1981
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