Golconda Mining Corp. v. Commissioner
United States Tax Court
Held: 1. The accumulated-earnings tax imposed under sec. 531, I.R.C. 1954, applies to a publicly held corporation whose management group is dominated by a single large shareholder or a small group of large shareholders that exercises effective control over the dividend policy of the company. 2. Although petitioner was primarily an investment company, it was not a mere holding or investment company within the meaning of sec. 533(b), I.R.C. 1954. 3. Petitioner is not subject…
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Held: 1. The accumulated-earnings tax imposed under sec. 531, I.R.C. 1954, applies to a publicly held corporation whose management group is dominated by a single large shareholder or a small group of large shareholders that exercises effective control over the dividend policy of the company. 2. Although petitioner was primarily an investment company, it was not a mere holding or investment company within the meaning of sec. 533(b), I.R.C. 1954. 3. Petitioner is not subject to the accumulated-earnings tax for the years 1962 through 1965 because its earnings and profits were not permitted to…
1Opinion of the Court
DawsoN, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
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Certain concessions liave been made by the parties. Tlie only issue to be decided is whether petitioner is subject to the accumulated-earnings tax imposed under section 5311 for the years 1962 through 1966.
FINDINGS OF FACT
Some of the facts hare been stipulated and are found accordingly.
Golconda Mining Corp. (herein called Golconda) is a corporation organized under the laws of the State of Idaho whose principal office was located in Wallace, Idaho, at the time it filed its…
2Cases cited18 opinions
- United States v. Donruss Co.Supreme Court of the United States · 1969
- Steelman v. All Continent Corp.Supreme Court of the United States · 1937
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Dixie, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
13 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Ivan Allen Co. v. United StatesSupreme Court of the United States · 1975
- Atlantic Properties, Inc. v. CommissionerUnited States Tax Court · 1974
- Golconda Mining Corp. v. CommissionerUnited States Tax Court · 1972
- Golconda Mining Corporation v. Commissioner of Internal Revenue, Golconda Mining Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
- Alma Piston Co. v. CommissionerUnited States Tax Court · 1976
13 more not listed; retrieve them via the Exa API.