Alex Brown, Inc. v. Commissioner of Internal Revenue

The taxpayer, a corporation, appeals from the decision of the United States Tax Court upholding a determination by the Commissioner of Internal Revenue of an income tax deficiency for its fiscal year ending May 31, 1969. The deficiency determination was based on a finding that the taxpayer was availed of for the purpose of avoiding federal income tax with respect to its shareholders within the meaning of the Internal Revenue Code provisions dealing with unreasonable accumulations, Sections 531 through 537.

Upon consideration of the record, briefs and oral arguments the court concludes that the…