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Snow Manufacturing Company v. Commissioner

86 T.C. 260 (1986)

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Snow Manufacturing Company v. Commissioner

United States Tax Court

86 T.C. 260 (1986)

Facts

Snow Manufacturing Company (plaintiff) dealt in automobile parts. As early as 1973, Snow Manufacturing developed a need for additional space for manufacturing and storage of parts—a need that became more pronounced as the company grew more profitable. In 1979 and 1980, Snow Manufacturing’s general manager met with several real estate brokers for the purpose of locating suitable property for expansion. The board of directors discussed and approved the purchase of a 30,000-square-foot building, but such property had yet to be found at the time of the meeting. Snow Manufacturing did not pay dividends in any tax year. The Commissioner of Internal Revenue (defendant) assessed an accumulated-earnings tax for 1979 and 1980 in response to perceived deficiencies. Snow Manufacturing challenged the assessment in the United States Tax Court, citing its need for expansion as the reason for its accumulation of earnings.

Rule of Law

Issue

Holding and Reasoning (Gerber, J.)

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