Legal Opinion

Henry Van Hummell, Inc. v. Commissioner

United States Tax Court

Decided November 5, 1964No. Docket No. 94312UnpublishedCited by 2 opinions

Petitioner, a family-owned corporation engaged in the business of representing a group for insurance purposes and acting as an insurance agent for insurance companies, retained a substantial portion of its earnings and profits for the years 1956 through 1959. It had previously accumulated a large earned surplus over a period of years. During this period petitioner paid substantial dividends and large salaries and bonuses to its stockholder-officers.

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Petitioner, a family-owned corporation engaged in the business of representing a group for insurance purposes and acting as an insurance agent for insurance companies, retained a substantial portion of its earnings and profits for the years 1956 through 1959. It had previously accumulated a large earned surplus over a period of years. During this period petitioner paid substantial dividends and large salaries and bonuses to its stockholder-officers. It also made substantial loans to an unaffiliated, inactive corporation, owned by the same family, of which it later acquired control. Held: The…

1Opinion of the Court

Henry Van Hummell, Inc. v. Commissioner.

Henry Van Hummell, Inc. v. Commissioner

Docket No. 94312.

United States Tax Court

T.C. Memo 1964-290; 1964 Tax Ct. Memo LEXIS 49; 23 T.C.M. (CCH) 1765; T.C.M. (RIA) 64290;

November 5, 1964

Petitioner, a family-owned corporation engaged in the business of representing a group for insurance purposes and acting as an insurance agent for insurance companies, retained a substantial portion of its earnings and profits for the years 1956 through 1959. It had previously accumulated a large earned surplus over a period of years. During this period petitioner paid…

2Cases cited30 opinions

  1. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  2. The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
  3. Dixie, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
  4. The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
  5. Pelton Steel Casting Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958

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3Cited by2 opinions

  1. Henry Van Hummell, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1966
  2. IVAN ALLEN COMPANY v. United StatesDistrict Court, N.D. Georgia · 1972

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