Legal Opinion

American Metal Products Corporation v. Commissioner of Internal Revenue, Adler Metal Products Corporation v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided March 29, 1961No. 16606_1PublishedCited by 61 opinions

1Opinion of the Court

MATTHES, Circuit Judge.

The ultimate question we have for determination in this proceeding to review the decisions of the Tax Court, is whether American Metal Products Corporation was availed of during 1952, 1953 and 1954, and Adler Metal Products Corporation was availed of during 1952 and 1954 for the purpose of avoiding the imposition of the surtax, or “income tax” upon their respective shareholders by permitting earnings or profits to accumulate beyond the reasonable needs of the business instead of being divided or distributed within the meaning of § 102 Internal Revenue Code 1939, 26…

2Cases cited9 opinions

  1. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  2. Boehm v. CommissionerSupreme Court of the United States · 1945
  3. Irving Sachs v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1960
  4. The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
  5. The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957

4 more not listed; retrieve them via the Exa API.

3Cited by61 opinions

  1. Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
  2. Estate of Craig M. Smith, Deceased, Ruth E. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  3. Estate of Goodall v. CommissionerCourt of Appeals for the Eighth Circuit · 1968
  4. J. Gordon Turnbull, Inc. v. CommissionerUnited States Tax Court · 1963
  5. Kansas City S. R. Co. v. CommissionerUnited States Tax Court · 1981

56 more not listed; retrieve them via the Exa API.

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