Hughes, Inc. v. Commissioner
United States Tax Court
Held, petitioner is not liable for the accumulated earnings tax because earnings and profits were not accumulated beyond the reasonable needs of its business.
1Opinion of the Court
WHITAKER, Judge:
In a statutory notice of deficiency dated January 20, 1984, respondent determined the following deficiencies in petitioner’s Federal income tax:
TYE Dec. 31— Amount
1979. $24,530
1980. 21,049
1981. 33,652
The issue for decision is whether petitioner is liable for the accumulated earnings tax imposed by section 531.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. Petitioner is a Florida corporation whose principal place of business is and has been in Orlando, Florida.
Petitioner’s sole shareholders upon incorporation were Russell S. Hughes, Harry C. Hughes,…
2Cases cited26 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- United States v. Donruss Co.Supreme Court of the United States · 1969
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
- Ivan Allen Co. v. United StatesSupreme Court of the United States · 1975
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3Cited by13 opinions
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- Network Systems Corp. v. United StatesDistrict Court, D. Minnesota · 1993
- Hughes, Inc. v. CommissionerUnited States Tax Court · 1988
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