F. E. Watkins Motor Co. v. Commissioner
United States Tax Court
Petitioner did not accumulate its earnings or profits beyond the reasonable needs of its business during the years 1951 and 1952 and petitioner was not availed of for the purpose of avoiding the surtax upon its shareholders within the meaning of section 102 of the Internal Revenue Code of 1939.
1Opinion of the Court
Arundell, Judge:
Respondent determined deficiencies in income tax for the calendar years 1951 and 1952 in the amounts of $17,568.51 and $15,131.24, respectively.
The only issue remaining is whether the respondent erred in determining that petitioner was subject to the surtax imposed by section 102 of the Internal Revenue Code of 1939, as amended, for each of the above-mentioned years. Another issue was raised by the pleadings but was abandoned at the hearing.
FINDINGS OF FACT.
Some of the facts were orally stipulated and are so found.
Petitioner is a Virginia corporation with its principal office…
2Cases cited8 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
- United Business Corporation v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1933
- Pelton Steel Casting Co. v. CommissionerUnited States Tax Court · 1957
- J. L. Goodman Furniture Co. v. CommissionerUnited States Tax Court · 1948
3 more not listed; retrieve them via the Exa API.
3Cited by48 opinions
- Dixie, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
- John P. Scripps Newspapers v. CommissionerUnited States Tax Court · 1965
- Bremerton Sun Publishing Co. v. CommissionerUnited States Tax Court · 1965
- Barrow Manufacturing Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
43 more not listed; retrieve them via the Exa API.