- 58 - Corp. v. Commissioner, 274 F.2d at 501. In other words, rather than being positive evidence demonstrating that NITCO's earnings were, in fact, accumulated to meet its reasonable business needs, these expenditures indicate NITCO's earnings were accumulated for the proscribed purpose of avoiding income tax with respect to its shareholders. See sec. 1.533-1(a)(2), Income Tax Regs. To accept petitioners' contention would be tantamount to holding that the accumulated earnings tax could be avoided by making nonbusiness expenditures to benefit a shareholder or shareholder's family. NITCO's Reasonable Business Needs The parties have stipulated, and we have so found, what NITCO's working capital requirements were during the years in issue. In addition to these working capital requirements, petitioners contend that a number of other reasonably anticipated business needs of NITCO justified NITCO's accumulation of earnings during the years in issue.12 12Petitioners contend that NITCO's "reasonably anticipated business needs" during the years in issue were as follows: Business Need 1987 1988 1989 Working capital $75,569 $278,646 $190,312 Retirement of long- 557,505 170,760 -0- term debt Plant modernization: Fiber to the exchange 1,000,000 same same (continued...)Page: Previous 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 Next
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