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HENRY C. BECK CO. v. COMMISSIONER

Docket No. 1686-66.

52 T.C. 1 (1969)

HENRY C. BECK COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 3, 1969.

Attorney(s) appearing for the Case

Sam G. Winstead and William D. Jordan, for the petitioners.

D. Ronald Morello and Ralph V. Bradbury, Jr., for the respondent.

DAWSON, Judge:

Respondent determined a deficiency in the income tax of petitioner for the year 1955 in the amount of $110,240.

The principal question for our consideration is whether an intercompany profit of $1,065,313.09 obtained in 1954 by Ridgeview Management Co., and eliminated from a consolidated return for that year, constituted earnings and profits of Ridgeview Management Co. when received, so that a distribution by Ridgeview Management Co....

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