American Metal Products Corp. v. Commissioner
United States Tax Court
1. Held: Adler Corporation was availed of during each of the years 1952 and 1954, and American Corporation was availed of during each of the years 1952, 1953, and 1954, for the purpose of preventing 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 section 102, I.R.C. 1939, and sections 531-…
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1. Held: Adler Corporation was availed of during each of the years 1952 and 1954, and American Corporation was availed of during each of the years 1952, 1953, and 1954, for the purpose of preventing 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 section 102, I.R.C. 1939, and sections 531- 537, I.R.C. 1954. Adler Corporation was not so availed of during the year 1953. 2. Reasonable rental value of property…
1Opinion of the Court
BRUCE, Judge:
These consolidated proceedings involve deficiencies in income tax in the following amounts:
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The issues are: (1) Whether either of the petitioners was availed of during any of the taxable years in question for the purpose of preventing the imposition of the surtax, or “income tax,” upon its shareholders by permitting earnings or profits to accumulate instead of being divided or distributed within the meaning of section 102, I.R.C. 1939, and sections 531-537, I.R.C. 1954; and (2) whether rental payments in excess of 20 cents per square foot per year by petitioners to…
2Cases cited23 opinions
- L. Schepp Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Place v. CommissionerUnited States Tax Court · 1951
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
- Pelton Steel Casting Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958
- Limericks, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
18 more not listed; retrieve them via the Exa API.
3Cited by54 opinions
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
- James Armour, Inc. v. CommissionerUnited States Tax Court · 1964
- J. Gordon Turnbull, Inc. v. CommissionerUnited States Tax Court · 1963
- Moffatt v. CommissionerUnited States Tax Court · 1964
- Kansas City S. R. Co. v. CommissionerUnited States Tax Court · 1981
49 more not listed; retrieve them via the Exa API.