Alma Piston Co. v. Commissioner
United States Tax Court
1. Held, petitioner was availed of during each of the years 1967 through 1969 for the purpose of avoiding the income tax with respect to its share-holders; the accumulated earnings tax imposed by section 531 is therefore applicable to the corporation's accumulated taxable income for each of such years. 2. Held, compensation paid to petitioner's president in excess of $ 150,000 in each of the years 1967 through 1969 was unreasonable and not deductible by the corporation under…
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1. Held, petitioner was availed of during each of the years 1967 through 1969 for the purpose of avoiding the income tax with respect to its share-holders; the accumulated earnings tax imposed by section 531 is therefore applicable to the corporation's accumulated taxable income for each of such years. 2. Held, compensation paid to petitioner's president in excess of $ 150,000 in each of the years 1967 through 1969 was unreasonable and not deductible by the corporation under section 162. 3. Held, the fair market value of property donated by petitioner to the Salvation Army in January 1967 was…
1Opinion of the Court
ALMA PISTON COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Alma Piston Co. v. Commissioner
Docket No. 5714-71.
United States Tax Court
T.C. Memo 1976-107; 1976 Tax Ct. Memo LEXIS 295; 35 T.C.M. (CCH) 464; T.C.M. (RIA) 760107;
April 6, 1976, Filed
1. Held, petitioner was availed of during each of the years 1967 through 1969 for the purpose of avoiding the income tax with respect to its share-holders; the accumulated earnings tax imposed by section 531 is therefore applicable to the corporation's accumulated taxable income for each of such years.
2. Held, compensation paid to…
2Cases cited33 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth 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
28 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Alma Piston Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1978
- Doug-Long, Inc. v. CommissionerUnited States Tax Court · 1979
- J.H. Rutter Rex Mfg. Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Central Motor Co. v. United StatesCourt of Appeals for the Tenth Circuit · 1978
- Snow Mfg. Co. v. CommissionerUnited States Tax Court · 1986
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