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YOUNG MOTOR COMPANY, INC. v. COMMISSIONER

Docket No. 62101.

32 T.C. 1336 (1959)

YOUNG MOTOR COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 30, 1959.

Attorney(s) appearing for the Case

Charles V. Ryan, Esq., for the petitioner.

John J. O'Toole, Esq., for the respondent.

Respondent determined deficiencies in petitioner's income tax of $15,791.88, $10,605.70, and $4,960.90 for the calendar years 1950, 1951, and 1952, respectively. The only issue is whether petitioner is subject to tax under section 102, I.R.C. 1939, as having been availed of during the taxable years to prevent the imposition of the surtax upon its shareholders by permitting earnings or profits to accumulate instead of being divided or distributed.

FINDINGS OF FACT...

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