Metro Leasing & Dev. Corp. v. Comm'r
United States Tax Court
In an earlier opinion, we decided that P permitted its 1995 earnings to accumulate beyond the reasonable needs of its business. Secs. 531- 537, I.R.C. There remains, however, a dispute concerning the computation of the accumulated earnings tax.
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In an earlier opinion, we decided that P permitted its 1995 earnings to accumulate beyond the reasonable needs of its business. Secs. 531- 537, I.R.C. There remains, however, a dispute concerning the computation of the accumulated earnings tax. P contends, alternatively, that R failed to reduce P's accumulated earnings tax base by the following amounts: (1) "Deferred" tax attributable to installment sale proceeds to be received by P in tax years after 1995; (2) the amount of the income tax deficiency determined by respondent which remains contested by P and for which P has made payment after…
1Opinion of the Court
METRO LEASING AND DEVELOPMENT CORPORATION, EAST BAY CHEVROLET COMPANY, A CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Metro Leasing & Dev. Corp. v. Comm'r
No. 8054-99
United States Tax Court
119 T.C. 8; 2002 U.S. Tax Ct. LEXIS 39; 119 T.C. No. 2;
July 17, 2002., Filed
Metro Leasing & Dev. Corp. v. Comm'r, T.C. Memo 2001-119, 2001 Tax Ct. Memo LEXIS 146 (T.C., 2001)
Petitioner not entitled to deduct tax on post-1995 installment sale income from taxable income in arriving at accumulated taxable income for 1995. No part of petitioner's paid, but contested, income tax…
Also in this document: Concurrence.
2Cases cited24 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. AndersonSupreme Court of the United States · 1926
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
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