COLOZZO
v.
UNITED STATES

U.S. | 1967-03-13
No. 873
386 U.S. 956 Supreme Court of the United States (1967) Positive Treatment
Cited by 1 case
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  • J.H. Rutter REX MFG. Co., Inc. v. Commissioner OF Internal Revenue, 853 F.2d 1275 (5th Cir. 1988)
    …ized as dividend payments. But the payment of large salaries and dividends to shareholder/employees does not overcome an otherwise objectionable accumulation, Henry Van Hummell, Inc. v. Commissioner, 364 F. 2d 746, 751 (10th Cir.1966), cert. denied, 386 U.S. 956, 87 S.Ct. 1019, 18 L.Ed.2d 102 (1967), although it might have some bearing on the tax avoidance/intent issue. . 26 I.R.C. § 533(a) creates a presumption of a tax avoidance motive if the corporation’s accumulations are unreasonable which is determin…

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