Ernest, Holdeman & Collet, Inc., a Corporation v. Commissioner of Internal Revenue

SCHNACKENBERG, Circuit Judge.

From the Tax Court’s decision determining deficiencies in income tax of Ernest, Holdeman & Collet, Inc., a corporation, petitioner, for the years 1952 and 1953, it appeals to this court.

Following the introduction of evidence, the Tax Court made findings of fact, the most salient of which we now state, in essential detail.

Petitioner, having its principal office in Elkhart, Indiana, was incorporated on December 29, 1947. It succeeded a partnership consisting of S. Vance Holdeman, Frederick I. Ernest, and his sons, Richard W. and Robert F. Ernest.

During the years…