Ivan Allen Co. v. United States
422 U.S. 617 (1975)

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U.S. Supreme Court

Ivan Allen Co. v. United States, 422 U.S. 617 (1975)

Ivan Allen Co. v. United States

No. 74-22

Argued April 115, 1975

Decided June 26, 1975

422 U.S. 617

Syllabus

In determining the applicability of § 533(a) of the Internal Revenue Code of 1954 -- which provides a rebuttable presumption that a corporation that has accumulated earnings "beyond the reasonable needs of the business" did so with "the purpose to avoid the income tax with respect to shareholders" -- listed and readily marketable securities owned by the corporation and purchased out of its earnings and profits are to be taken into account not at their cost to the corporation, but at their net liquidation value. Pp. 422 U. S. 624-635.

493 F.2d 426, affirmed.

BLACKMUN, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, MARSHALL, and REHNQUIST, JJ., joined. POWELL, J., filed a dissenting opinion, in which DOUGLAS and STEWART, JJ., joined, post, p. 422 U. S. 635.

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