 | United States. Tax Court - Law reports, digests, etc - 1967 - 786 pages
...being divided or distributed. Section 533 (a) provides that the fact that the earnings and profits are permitted to accumulate beyond the reasonable...with respect to shareholders, unless the corporation shall prove to the contrary. Section 533 (b) provides that the fact that a corporation is a mere holding... | |
 | Administrative law - 1988 - 552 pages
...shareholders is subject to disproof by competent evidence. Section 533(a) provides that the fact that earnings and profits of a corporation are permitted...preponderance of the evidence, shall prove to the contrary. The burden of proving that earnings and profits have been permitted to accumulate beyond the reasonable... | |
 | Administrative law - 1992 - 584 pages
...shareholders is subject to dis proof by competent evidence. Section 533(a) provides that the fact that earnings and profits of a corporation are permitted...income tax with respect to shareholders unless the corpora tion, by the preponderance of the evidence, shall prove to the contrary. The burden of proving... | |
 | Administrative law - 1961 - 566 pages
...shareholders is subject to disproof by competent evidence. Section 533 (a) provides that the fact that earnings and profits of a corporation are permitted...preponderance of the evidence, shall prove to the contrary. The burden of proving that earnings and profits have been permitted to accumulate beyond the reasonable... | |
 | United States. Congress. Senate. Committee on Finance - Depreciation allowances - 1962 - 1080 pages
...earnings and profits to accumulate instead of being divided or distributed * * *. " * * * the fact that earnings and profits of a corporation are permitted...preponderance of the evidence, shall prove to the contrary." The phrase "ordinary and necessary" is understandable when related to the deductibllity of business... | |
 | United States. Tax Court - Taxation - 1963 - 1156 pages
...had been other than a personal holding company during this period and had experienced a « SEC. 538. EVIDENCE OF PURPOSE TO AVOID INCOME TAX. (a) UNREASONABLE...preponderance of the evidence shall prove to the contrary. similar history. While at the Commissioner's request we have made extended findings of fact concerning... | |
 | United States. Tax Court - Taxation - 1965 - 888 pages
...« SEC. 533. EVIDENCE OF PURPOSE TO AVOID INCOME TAX. (a) UNREASONABLE ACCUMULATION DETERMINATIVE OP PURPOSE. — For purposes of section 532, the fact...business shall be determinative of the purpose to uvold the Income tax with respect to shareholders, unless the corporation by the preponderance of the... | |
 | United States. Internal Revenue Service - Tax administration and procedure - 1977 - 632 pages
...earnings and profits to accumulate instead of being distributed. Section 533 (a) of the Code states that for purposes of section 532, the fact that the earnings...preponderance of the evidence shall prove to the contrary. Section 533 (b) of the Code states that the fact that any corporation is a mere holding or investment... | |
 | United States. Tax Court - Taxation - 1979 - 1352 pages
...income tax with respect to its shareholder (Longway) during the years in issue. Section 533(a) provides: For purposes of section 532, the fact that the earnings...preponderance of the evidence shall prove to the contrary. In this case, we have concluded that in each of the years in issue petitioner's earnings and profits... | |
 | United States. Supreme Court - Courts - 1969 - 1136 pages
...and profits to accumulate instead of being divided or distributed." ' Section 533 (a) provides that: "For purposes of section 532, the fact that the earnings...preponderance of the evidence shall prove to the contrary." In cases before the Tax Court, § 534 allows the taxpayer in certain instances to shift to the Commissioner... | |
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... reasonable needs of the business shall be determinative of the purpose to avoid the income tax with respect to shareholders, unless the corporation by the preponderance of the evidence shall prove to the contrary. * * * SEC. 537. REASONABLE NEEDS... 
