A. T. Williams Oil Co. v. Commissioner
United States Tax Court
Held, petitioner was availed of for the purpose of avoiding the income tax with respect to its shareholders.
1Opinion of the Court
A. T. WILLIAMS OIL COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
A. T. Williams Oil Co. v. Commissioner
Docket No. 1143-78.
United States Tax Court
T.C. Memo 1981-461; 1981 Tax Ct. Memo LEXIS 279; 42 T.C.M. (CCH) 851; T.C.M. (RIA) 81461;
August 26, 1981.
Held, petitioner was availed of for the purpose of avoiding the income tax with respect to its shareholders.
Leon L. Rice, Jr. and Thomas L. Kummer, for the petitioner.
Frank D. Armstrong, Jr., for the respondent.
IRWIN
MEMORANDUM FINDINGS OF FACT AND OPINION
IRWIN, Judge: Respondent determined an accumulated earnings tax pursuant…
2Cases cited37 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- 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
- Palmer v. CommissionerUnited States Tax Court · 1974
- Daniel D. And Agnes H. Palmer v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1975
32 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- J.H. Rutter Rex Mfg. Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988