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YATES PETROLEUM CORPORATION v. COMMISSIONER

Docket No. 2729-91.

63 T.C.M. 2347 (1992)

T.C. Memo. 1992-146

Yates Petroleum Corporation v. Commissioner.

United States Tax Court.

Filed March 12, 1992.

Attorney(s) appearing for the Case

Karl Norman Clifford and Stephen J. Stone, 2112 Indiana, Lubbock, Tex., for the petitioner. Martin M. Van Brauman, for the respondent.

Memorandum Opinion

BEGHE, Judge:

This opinion addresses respondent's motion under Rule 142(e)1 to allocate the burden of proof on the reasonableness of petitioner's alleged business needs for accumulated earnings tax purposes. Respondent determined that petitioner was liable for the accumulated earnings tax imposed by section 531 for the fiscal year ended March 31, 1988, in the amount of $5,281,073. Petitioner contends that its...

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