Marie's Shoppe, Inc. v. Commissioner
United States Tax Court
Petitioner had accumulated earnings and profits for the years 1971, 1972 and 1973 of $161,535.78, $178,368.06 and $192,785.49, respectively. Held, petitioner had accumulated these earnings and profits to capitalize moving, expanding or remodeling the business premises; to meet contingent liabilities; and to cover working capital needs. Held further, avoidance of income tax with respect to its shareholders was not the purpose of such accumulations.
1Opinion of the Court
MARIE'S SHOPPE, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Marie's Shoppe, Inc. v. Commissioner
Docket Nos. 6901-74 5023-76
United States Tax Court
T.C. Memo 1977-381; 1977 Tax Ct. Memo LEXIS 67; 36 T.C.M. (CCH) 1548; T.C.M. (RIA) 770381;
October 31, 1977, Filed
Petitioner had accumulated earnings and profits for the years 1971, 1972 and 1973 of $161,535.78, $178,368.06 and $192,785.49, respectively. Held, petitioner had accumulated these earnings and profits to capitalize moving, expanding or remodeling the business premises; to meet contingent liabilities; and to cover…
2Cases cited18 opinions
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- United States v. Donruss Co.Supreme Court of the United States · 1969
- 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
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3Cited by2 opinions
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