The Taxation of Corporate Surplus Accumulations: The Application and Effect, Real and Feared, of Section 102 of the Internal Revenue Code Dealing with Unreasonable Accumulation of Corporate Profits, Volume 7; Volume 19U.S. Government Printing Office, 1952 - 260 pages |
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Common terms and phrases
102 net income accumulation of surplus amendment amount application assessable tax assessed corporations assets to current avoid surtax Bureau of Internal Certiorari closely held Congress corporate earnings corporate liquidity corporate tax current assets current liabilities December 31 deficiency assessments dends dividend distributions dividends du Pont family earned surplus effect enforcement excess Finance fiscal Ibid Income Tax Unit Internal Revenue Bulletin Internal Revenue Code July 26 liquid assets ment nonassessable tax number of corporations number of stockholders Number of tax P-H Memo T. C. penalty tax period personal holding companies personal tax porate posttax net income purpose to avoid questionnaire quick assets ratio of current reasonable needs retained earnings retention of earnings Revenue Act revenue agent shareholders shares statute surtax rates tax assessed tax avoidance Tax Court taxable taxation tion total assets total number Trico Products Corp unreasonable accumulation voting stock
Popular passages
Page 184 - The fact that the earnings or profits of a corporation are permitted to accumulate beyond the reasonable needs of the business shall be determinative of the purpose to avoid surtax upon shareholders unless the corporation by the clear preponderance of the evidence shall prove to the contrary.
Page 194 - ... the fact that any such corporation, joint-stock company or association, or insurance company, is a mere holding company, or that the gains and profits are permitted to accumulate beyond the reasonable needs of the business...
Page 201 - P) if such corporation, however created or organized, is formed or availed of for the purpose of preventing the imposition of the surtax upon its shareholders or the shareholders of any other corporation, through the medium of permitting earnings or profits to accumulate instead of being divided or distributed...
Page 130 - Where before the expiration of the time prescribed in section 275 for the assessment of the tax, both the Commissioner and the taxpayer have consented in writing to its assessment after such time, the tax may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon.
Page 206 - ... if such associations or corporations engage in business for the common benefit of the members, but only if the members thereof include (at the time of filing their returns) in their gross income their entire pro rata shares, whether distributed or not, of the taxable income of the association or corporation for such year.
Page 249 - Commissioner therefore determines that the corporation was formed or availed of for the purpose of avoiding...
Page 228 - Credit" means the sum of: (1) The dividends paid during the taxable year, increased by the consent dividends credit provided in section 28, and reduced by the amount of the credit provided in section 26 (a), relating to interest on certain obligations of the United States and Government corporations...
Page 225 - Federal income, war-profits, and excess-profits taxes paid or accrued during the taxable year, to the extent not allowed as a deduction by section 23, but not including the tax imposed by this section or a corresponding section of a prior income-tax law. (B) DISALLOWED CHARITABLE, ETC., CONTRIBUTIONS. — Contributions or gifts payment of ,which is made within the taxable year, not otherwise allowed as a deduction, to or for the use of donees described in section 23 (o) , for the purposes therein...
Page 201 - The fact that any corporation is a mere holding or investment company, or that the gains or profits are permitted to accumulate beyond the reasonable needs of the business, shall be prima facie evidence of a purpose to escape the surtax.
Page 252 - The last day so computed is to be included, unless it is a Saturday, Sunday or legal holiday in the District of Columbia, in which event the period shall run until the end of the next day which is neither a Saturday, Sunday nor legal holiday.