Many of the relevant facts and figures are contained in a stipulation, supported by a mass of documents, and in a tentative stipulation dealing with events which occurred after April 30, 1962, likewise supported by documents. ![]() The principal subsidiary issues are: (I) whether in either or both years taxpayer's earnings and profits were permitted to accumulate beyond the reasonable needs of the business, including the reasonably anticipated needs of the business and (II) if they were, whether taxpayer has proved that such accumulations were not made for the purpose of avoiding the income tax with respect to its stockholders. The ultimate question to be decided is whether taxpayer was availed of during either or both of those years for the purpose of avoiding income tax with respect to its stockholders by permitting earnings and profits to accumulate instead of being distributed. In this action, tried before the Court without a jury, plaintiff (taxpayer) seeks recovery of accumulated earnings taxes and interest thereon, assessed against and paid by it for its taxable years ended Ap($339,602.23) and Ap($300,526.39). Atty., Baltimore, Md., on the brief), for defendant. Anderson, Atty., Civil Tax Division, Washington, D. *282 Moshe Schuldinger and Richard Seidman, Attys., Civil Tax Division, Dept. ![]() (Niles, Barton & Wilmer, Baltimore, Md., and Epstein and Friedman and Ginsburg & Feldman, Washington, D.
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