Belaire Management Corp. v. Commissioner
United States Tax Court
Sec. 102, I. R. C. -- Accumulations Beyond Business Needs. -- An advertising and promotion agent for a Canadian whiskey bottler reimbursed monthly by the client for all expenditures made for the client, accumulated the earnings of its first year of operation beyond the reasonable needs of its business and was subject to tax under section 102 of the Internal Revenue Code.
1Opinion of the Court
Belaire Management Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Belaire Management Corp. v. Commissioner
Docket No. 38987
United States Tax Court
21 T.C. 881; 1954 U.S. Tax Ct. LEXIS 271;
March 15, 1954, Promulgated
Decision will be entered for the respondent.
Sec. 102, I. R. C. -- Accumulations Beyond Business Needs. -- An advertising and promotion agent for a Canadian whiskey bottler reimbursed monthly by the client for all expenditures made for the client, accumulated the earnings of its first year of operation beyond the reasonable needs of its business and was…
2Cases cited4 opinions
- Jacob Sincoff, Inc. v. CommissionerUnited States Tax Court · 1953
- Gibbs & Cox, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Jacob Sincoff, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
- Belaire Management Corp. v. CommissionerUnited States Tax Court · 1954