J. L. Goodman Furniture Co. v. Commissioner
United States Tax Court
1. Section 102 -- Improper Accumulation of Corporate Surplus. -- The taxpayer has shown reasonable business needs for its accumulated earnings.
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1. Section 102 -- Improper Accumulation of Corporate Surplus. -- The taxpayer has shown reasonable business needs for its accumulated earnings. It was not formed or availed of in 1942 or 1943 for the purpose of preventing the imposition of the surtax upon its shareholders through the medium of permitting its earnings or profits to accumulate instead of being divided or distributed. 2. Excess Profits Tax -- Equity Invested Capital -- Accumulated Earnings and Profits -- Uncollected Gross Profits on Installment Sales -- Sections 718 (a) (4), 736 (a). -- The petitioner is not entitled to include…
1Opinion of the Court
OPINION.
Murdock, Judge:
It is conceded that the petitioner was not formed for the purpose of avoiding surtax on its shareholders and was not a mere holding or investment company. Both parties recognize that the earnings for each year may be reduced by the actual or estimated amounts necessary to pay Federal taxes. There is no substantial difference between the amount of earnings shown on the income tax returns for each year and the amount determined by the Commissioner to be correct, but it so happens that there were unusually large collections during these years, so that the income shown on…
2Cases cited6 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- General Smelting Co. v. CommissionerUnited States Tax Court · 1944
- Kimbrell's Home Furnishings, Inc. v. CommissionerUnited States Tax Court · 1946
- Mackin Corp. v. CommissionerUnited States Tax Court · 1946
- Basalt Rock Co. v. CommissionerUnited States Tax Court · 1948
1 more not listed; retrieve them via the Exa API.
3Cited by59 opinions
- Dixie, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
- John P. Scripps Newspapers v. CommissionerUnited States Tax Court · 1965
- Pelton Steel Casting Co. v. CommissionerUnited States Tax Court · 1957
- Bremerton Sun Publishing Co. v. CommissionerUnited States Tax Court · 1965
54 more not listed; retrieve them via the Exa API.