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METAL OFFICE FURNITURE COMPANY v. COMMISSIONER

Docket Nos. 107369 and 238.

11 T.C.M. 1066 (1952)

Metal Office Furniture Company v. Commissioner.

United States Tax Court.

Entered October 28, 1952.

Attorney(s) appearing for the Case

J. S. Seidman, C. P. A., F. E. Seidman, C. P. A., and L. W. Seidman, Esq., for the petitioner. A. J. Friedman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined deficiencies in income tax of $44,023.54 for 1938, $32,531.52 for 1939 and $46,236.12 for 1940. The only issue for decision is whether the petitioner was availed of during one or more of the taxable years for the purpose of preventing the imposition of surtax upon its shareholders through the medium of permitting its earnings and profits for the taxable years to accumulate beyond the reasonable...

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