Phillip B. Hardin v. United States of America, Hardin's Bakeries Corporation v. United States of America, (Two Cases)

461 F.2d 865, 29 A.F.T.R.2d (RIA) 1446, 1972 U.S. App. LEXIS 9157
CourtCourt of Appeals for the Fifth Circuit
DecidedJune 7, 1972
Docket71-1049, 71-1405, 71-1406
StatusPublished
Cited by38 cases

This text of 461 F.2d 865 (Phillip B. Hardin v. United States of America, Hardin's Bakeries Corporation v. United States of America, (Two Cases)) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Phillip B. Hardin v. United States of America, Hardin's Bakeries Corporation v. United States of America, (Two Cases), 461 F.2d 865, 29 A.F.T.R.2d (RIA) 1446, 1972 U.S. App. LEXIS 9157 (5th Cir. 1972).

Opinion

JOHN R. BROWN, Chief Judge:

In this consolidated appeal of three Federal income tax refund suits the score thus far stands 2-1 in favor of the Government. The opposing line-up consists of Phillip B. Hardin (Taxpayer) and two of his wholly owned corporations manufacturing bread and other bakery *867 products in Mississippi. 1 Both corporations were thrown out in a double play when the District Court concluded that they had retained earnings and profits in amounts exceeding their reasonable business needs for the purpose of income tax avoidance and were therefore subject to the accumulated earnings tax imposed by Subchapter G of the Internal Revenue Code of 1954 2 Taxpayer averted a shut-out when the Court held that certain payments made by Hardin’s Bakeries Corp. to Taxpayer’s sister-in-law, while not deductible by the corporation as an ordinary and necessary business expense, were nevertheless also not includable in his gross income as informal or “constructive” dividends. Both sides seek an instant appellate replay.

The replay shows the Government should sweep the series. We affirm the judgments for the United States because the issues contested by the corporate taxpayers involve essentially factual questions resolved adversely by the District Court on the basis of findings that are not clearly erroneous. We reverse the judgment in favor of Taxpayer because on virtually any theory of the case the corporate payments made at his direction to his deceased brother’s wife constituted taxable income to him.

The Corporations (7l-lJj05 and 71— U06)

Both Hardin’s Bakeries Corp. and Hardin’s Bakeries, Inc. operate wholesale bakery businesses in northern Mississippi. Evolving from a family partnership consisting of Taxpayer and his brothers and sisters, the corporations are exclusively controlled by Taxpayer, who owns all of the capital stock and is the chief executive officer of each firm. During the taxable years in question (1964 and 1965) most of the day-to-day operations of both businesses were carried on by a committee because of Taxpayer’s illness, although he continued to supervise and approve most of the major decisions involving capital expenditures.

During this period both corporations accumulated substantial earned surpluses, consisting mostly of cash and other liquid assets, of which a substantial proportion was available for utilization as working capital or for the payment of *868 dividends. 3 However, neither corporation had ever declared a dividend since the reorganization of the family partnership in 1944-45, and had all available accumulated earnings (above the amount, as computed by the Government necessary for working capital) been paid out as dividends during 1964-65 Taxpayer’s additional Federal income tax liability would have amounted to approximately $135,000. 4 On this basis the Commissioner determined that the retention of earnings by both corporations constituted an attempt to reduce Taxpayer’s individual personal income tax liability, resulting in the assessment of the accumulated earnings tax.

In their suits for refund both corporations contended that they had reasonably anticipated working capital requirements exceeding their accumulated surpluses 5 and that the tax was not imposable, ei *869 ther because the accumulations in question were within their legitimate business needs or because the purpose for the accumulations was not the avoidance of Federal income taxes. Rejecting both of these arguments, the District Court found that there was no substantial evidence supporting the corporations’ position regarding the purposes for the accumulations, that none of the amounts accumulated were actually expended for the alleged purposes advanced to justify them, and that their respective surpluses were unreasonable in amount when considered in connection with the reasonably anticipated capital requirements of the businesses. 6

Significantly, the law does not require a finding that a corporation’s earnings have been accumulated exclusively or primarily for the purpose of averting Federal income tax liabilities for its shareholders. It is sufficient if a tax avoidance motive was one of the underlying purposes. United States v. Donruss Co., 1969, 393 U.S. 297, 301, 89 S.Ct. 501, 503, 21 L.Ed.2d 495, 500; Barrow Mfg. Co. v. Commissioner, 5 Cir., 1961, 294 F.2d 79, 82, cert. denied, 1962, 369 U.S. 817, 82 S.Ct. 827, 7 L.Ed.2d 783. Since § 533(a) of the Code provides that accumulations beyond reasonable business needs shall be determinative of a tax avoidance purpose “unless the corporation by the preponderance of the evidence shall prove to the contrary” (see note 2, supra), both corporations were in effect burdened with disproving an unacceptable motive if their retained earnings during the taxable years in question were in fact excessive. Mead’s Bakery, Inc. v. Commissioner, 5 Cir., 1966, 364 F.2d 101. 7 Thus, the District Court’s finding that the accumulations of both corporations exceeded their reasonable working capital, requirements is really the only issue seriously in dispute because the evidence advanced to establish legitimate motives, including that involving Taxpayer’s conservative finan *870 cial policies and the losses resulting from a plant fire, falls far short of that requisite to overcome the inference of presumptive unacceptability entailed by excessive retention of earnings. Both corporations may very well have had a variety of legitimate, nontax motives — to some or all of which their financial policies may be attributed- — but a concession of their existence does not mandate the conclusion that tax avoidance played no role in the matter. Absent clear error the District Court’s finding of a proscribed purpose must stand. Battelstein Investment Co. v. United States, 5 Cir., 1971, 442 F.2d 87, 88; cf. Scroll, Inc. v. Commissioner, 5 Cir., 1971, 447 F.2d 612, 619-20.

Whether the District Court correctly concluded that earnings were accumulated beyond the reasonable business needs of the corporations depends almost entirely upon the validity of the evi-dentiary criteria that were utilized to assess “reasonableness,” particularly the method by which the corporations’ need for working capital was determined by reference to the amount required to carry them through one complete operating cycle. 8

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461 F.2d 865, 29 A.F.T.R.2d (RIA) 1446, 1972 U.S. App. LEXIS 9157, Counsel Stack Legal Research, https://law.counselstack.com/opinion/phillip-b-hardin-v-united-states-of-america-hardins-bakeries-ca5-1972.