Snow Mfg. Co. v. Commissioner
United States Tax Court
P, a wholly owned subsidiary of a closely held corporation, remanufactured automobile parts. R determined that P was subject to the accumulated earnings tax for its taxable years ended June 30, 1979, and June 30, 1980. The parties disagreed as to whether P's reasonable business needs for fiscal 1979 and 1980 included the need to accumulate funds for expansion or relocation of its plant.
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P, a wholly owned subsidiary of a closely held corporation, remanufactured automobile parts. R determined that P was subject to the accumulated earnings tax for its taxable years ended June 30, 1979, and June 30, 1980. The parties disagreed as to whether P's reasonable business needs for fiscal 1979 and 1980 included the need to accumulate funds for expansion or relocation of its plant. The parties also disagreed about computation of the credit cycle in connection with the working capital analysis of Bardahl v. Commissioner, T.C. Memo. 1965-200. The parties further disagreed as to whether…
1Opinion of the Court
Snow Manufacturing Company, a Dissolved California Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Snow Mfg. Co. v. Commissioner
Docket No. 25950-82
United States Tax Court
86 T.C. 260; 1986 U.S. Tax Ct. LEXIS 147; 86 T.C. No. 18;
March 4, 1986, Filed
Decision will be entered under Rule 155.
P, a wholly owned subsidiary of a closely held corporation, remanufactured automobile parts. R determined that P was subject to the accumulated earnings tax for its taxable years ended June 30, 1979, and June 30, 1980. The parties disagreed as to whether P's reasonable business needs for…
2Cases cited28 opinions
- United States v. Donruss Co.Supreme Court of the United States · 1969
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Dixie, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
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