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READY PAVING & CONSTRUCTION CO. v. COMMISSIONER

Docket No. 2324-72.

61 T.C. 826 (1974)

READY PAVING & CONSTRUCTION CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 26, 1974.

Attorney(s) appearing for the Case

Barry E. Semer and Aaron Cohen, for petitioner.

Lewis M. Porter, Jr., for respondent.

OPINION

SCOTT, Judge:

Respondent determined deficiencies in accumulated-earnings taxes of petitioner for the taxable years ending December 31, 1966 and 1967, in the respective amounts of $10,468.54 and $5,890.08. The only issue for decision is whether petitioner was availed of for the purpose of avoiding additional Federal income taxes with respect to its shareholders in each of the years in issue.

All the facts have been stipulated and all...

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