26 U.S.C. § 531
Imposition of accumulated earnings tax
In addition to other taxes imposed by this chapter, there is hereby imposed for each taxable year on the accumulated taxable income (as defined in section 535) of each corporation described in section 532, an accumulated earnings tax equal to 20 percent of the accumulated taxable income.
Notes of Decisions
Cited in 40
cases (1 in the last 5 years), 1961–2024 · leading case: Metro Leasing & Dev. Corp. East Bay Chevrolet Co., a Corp. v. Comm'r of Internal Revenue, 376 F.3d 1015 (9th Cir. 2004).
Metro Leasing & Dev. Corp. East Bay Chevrolet Co., a Corp. v. Comm'r of Internal Revenue, 376 F.3d 1015 (9th Cir. 2004). “B In 1995, 26 U.S.C. § 531 imposed a 39.6% tax on the amount of income that a *1022 corporation had unreasonably accumulated (known for purposes of the Internal Revenue Code as the corporation’s “accumulated taxable income”).”
United States v. Generes, 405 U.S. 93 (1972). “We see no inconsistency, such as the taxpayer suggests, between the Government's urging dominant motivation here and its having urged only significant motivation as the appropriate standard for the incurrence of liability for the accumulated-earnings tax under § 531 of the 1954…”
Ivan Allen Co. v. United States, 422 U.S. 617 (1975). “[2] For the purpose of determining the applicability of the additional penalty tax liability under 26 U. S. C. § 531 , the Commissioner valued these securities at their year-end market price.”
Catherine Wilson Nolen, on Behalf of Herself & All Other Stockholders of the Shaw-Walker Co. v. The Shaw-Walker Co., 449 F.2d 506 (6th Cir. 1971). “of *507 the Internal Revenue Code of 1954, as amended, 26 U.S.C. § 531 et seq., for excessive accumulations of earnings during the Company’s taxable years ended June 30, 1955, 1956, and 1957, and $846,642.”
Presbyterian & Reformed Publ'g Co. v. Comm'r of Internal Revenue, 743 F.2d 148 (3rd Cir. 1984). “Although no regulations govern cash accumulations in the 501(c)(3) context, we are guided by the accumulated earnings tax, 26 U.S.C. § 531 et seq. (1982). The accumulated earnings provision of the Tax Code was designed to weed out illegitimate non-payment of dividends by…”
Motor Fuel Carriers, Inc. v. Comm'r of Internal Revenue, 559 F.2d 1348 (5th Cir. 1977). “26 U.S.C. §§ 531 et seq. The government determined deficiencies in taxpayer’s income tax for years 1968, 1969 and 1970 of roughly $59,000, $63,000 and $51,000, respectively.”
Road Materials, Inc. v. Comm'r of Internal Revenue, Comm'r of Internal Revenue v. Road Materials, Inc., 407 F.2d 1121 (4th Cir. 1969). “Code of 1954, § 531 [ 26 U.S.C. § 531 (1967)]. In No. 12,501, the Corn-missioner seeks reversal and remand on this question only if we should reverse on the debt issue in No.”
Simons-E. Co. v. United States, 354 F. Supp. 1003 (N.D. Ga. 1972). “29 as *1005 sessed by the government as accumulated earnings taxes under Section 531 of the Internal Revenue Code of 1954 ( 26 U.S.C. § 531 ) for the fiscal years ending January 31, 1966, 1967 and 1968.”
Motor Fuel Carriers, Inc. v. United States, 202 F. Supp. 497 (N.D. Fla. 1962). “The Commissioner of Internal Revenue in auditing the taxpayer’s returns for 1956 and 1957 determined that the corporation had unreasonably accumulated its earnings for those years and imposed the surtax provided for in Section 531 of the Internal Revenue Code of 1954, 26 U.S.C.…”
Nemours Corp. v. Comm'r of Internal Revenue, 325 F.2d 559 (3rd Cir. 1963). “During the trial, the Commissioner, after he had amended his answer to the petition, abandoned his former claim and determined that the taxpayer was deficient in a lesser amount *560 on the ground that it was subject to the accumulated earnings tax under §§ 531 and 532 of the…”
Battelstein Inv. Co. v. United States, 442 F.2d 87 (5th Cir. 1971). “This is an appeal by Taxpayer (Bat-telstein Investment Company) from an adverse tax refund judgment the effect of which is to sustain the Government’s contention that there was an unreasonable accumulation of earnings setting in train the accumulated earnings tax under 26…”
The Cheyenne Newspapers, Inc. v. Comm'r of Internal Revenue, 494 F.2d 429 (10th Cir. 1974). “26 U.S.C. § 531 provides : In addition to other taxes imposed by this chapter, there is hereby imposed for each taxable year on the accumulated taxable income (as defined in section 535) of every corporation described in section 532, an accumulated earnings tax equal to the sum…”
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