Dixie, Inc. v. Commissioner
United States Tax Court
Held, petitioner accumulated earnings and profits beyond the reasonable needs of its business in 1952 and petitioner was availed of for the purpose of preventing the imposition of surtax upon its shareholder within the meaning of section 102 of the Internal Revenue Code of 1939.
1Opinion of the Court
Train, Judge:
Respondent determined a deficiency in petitioner’s income tax for the taxable year 1952 in the amount of $22,053.11. The sole issue for decision is whether petitioner is subject to the surtax imposed by section 102 of the Internal Revenue Code of 1939 with respect to corporations improperly accumulating surplus.
BINDINGS OP PACT.
Some of the facts are stipulated and are hereby found as stipulated.
Petitioner, The Dixie, Inc. (hereinafter referred to as Dixie), is a corporation which was organized under the laws of the State of New York on March 23, 1942, and at all times pertinent…
2Cases cited2 opinions
- K O M A, Inc. v. Commissioner of Internal Revenue. Tulsa Broadcasting Co. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1951
- McCutchin Drilling Co. v. Commissioner of Internal Rev.Court of Appeals for the Fifth Circuit · 1944
3Cited by68 opinions
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
- John P. Scripps Newspapers v. CommissionerUnited States Tax Court · 1965
- Bremerton Sun Publishing Co. v. CommissionerUnited States Tax Court · 1965
- Barrow Manufacturing Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
- American Metal Products Corp. v. CommissionerUnited States Tax Court · 1960
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