YOUNGS RUBBER CORPORATION v. C. I. R.

No. 56, Docket 28170.

331 F.2d 12 (1964)

YOUNGS RUBBER CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided April 17, 1964.


Attorney(s) appearing for the Case

Vincent J. Jennings, Newark, N. J. (Robert W. Brady, Newark, N. J., of counsel), for petitioner.

John M. Brant, Attorney, Department of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Meyer Rothwacks and David O. Walter, Attorneys, Department of Justice, Washington, D. C.), for respondent.

Before MOORE, FRIENDLY and KAUFMAN, Circuit Judges.


PER CURIAM.

Taxpayer appeals from a decision of the Tax Court, T.C.Mem. 1962-300, sustaining the Commissioner's assessment of a penalty tax under section 531 of the Internal Revenue Code of 1954 on accumulated earnings for the year 1956.

Taxpayer replied to the Commissioner's section 534(b) notification with a statement of the grounds on which it relied pursuant to section 534(c). That statement, consisting of various items summarized under five major grounds...

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