Casey v. Commissioner
United States Tax Court
Held: 1. Bankers did not accumulate its earnings and profits beyond the reasonable needs of its business during the years ended April 30, 1948 and April 30, 1949, and that Bankers was not availed of for the purposes of avoiding the surtax upon its shareholders within the meaning of section 102, I.R.C. 1939. 2. Bankers accumulated its earnings and profits beyond the reasonable needs of its business during the year ended April 30, 1950 and was availed of for the purpose of…
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Held: 1. Bankers did not accumulate its earnings and profits beyond the reasonable needs of its business during the years ended April 30, 1948 and April 30, 1949, and that Bankers was not availed of for the purposes of avoiding the surtax upon its shareholders within the meaning of section 102, I.R.C. 1939. 2. Bankers accumulated its earnings and profits beyond the reasonable needs of its business during the year ended April 30, 1950 and was availed of for the purpose of preventing the imposition of surtax upon its shareholders and, accordingly, is liable for the surtax under section 102 for…
1Opinion of the Court
Jerome E. Casey, Transferee of the Assets of Bankers Development Corporation v. Commissioner.
Casey v. Commissioner
Docket No. 59388.
United States Tax Court
T.C. Memo 1957-226; 1957 Tax Ct. Memo LEXIS 23; 16 T.C.M. (CCH) 1024; T.C.M. (RIA) 57226;
December 10, 1957
Held: 1. Bankers did not accumulate its earnings and profits beyond the reasonable needs of its business during the years ended April 30, 1948 and April 30, 1949, and that Bankers was not availed of for the purposes of avoiding the surtax upon its shareholders within the meaning of section 102, I.R.C. 1939.
2. Bankers accumulated its…
2Cases cited6 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Helvering v. Chicago Stock Yards Co.Supreme Court of the United States · 1943
- Gus Blass Co. v. CommissionerUnited States Tax Court · 1947
- Corporate Inv. Co. v. CommissionerUnited States Board of Tax Appeals · 1939
- C. H. Spitzner & Son, Inc. v. CommissionerUnited States Board of Tax Appeals · 1938
1 more not listed; retrieve them via the Exa API.