Eyefull Incorporated - Page 26

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          TYE 8/31/88, $702,000 in TYE 8/31/90, and $306,000 in TYE                   
          8/31/91.                                                                    
                                     Discussion                                       
               Section 531 imposes a penalty tax on the accumulated taxable           
          income of a corporation that is availed of for the purpose of               
          avoiding tax with respect to its shareholders by permitting                 
          earnings and profits to accumulate instead of distributing them.            
          Secs. 531, 532(a).  The fact that earnings and profits have                 
          accumulated beyond the reasonable needs of the business                     
          establishes a presumption that tax avoidance was a purpose of the           
          accumulation.  Sec. 533(a).  The reasonable needs of the business           
          include reasonably anticipated future needs.  Sec. 1.537-1(a),              
          Income Tax Regs.  In order to justify an accumulation for                   
          reasonably anticipated future needs, in general, the corporation            
          must demonstrate a need warranting such accumulation and the                
          existence, as of the end of the relevant taxable year, of                   
          specific, definite, and feasible plans to use the accumulation              
          within a reasonable time to meet this need.  Sec. 1.537-1(b),               
          Income Tax Regs.  In recognition of the informality which                   
          commonly characterizes planning within a closely held                       
          corporation, neither the regulations nor the cases require                  
          meticulously drawn formal blueprints for action.  Faber Cement              
          Block Co. v. Commissioner, 50 T.C. 317, 332 (1968); Bremerton Sun           
          Publishing Co. v. Commissioner, 44 T.C. 566, 584-585 (1965).  But           
          where such documentation is lacking, the intention to dedicate              




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