Furthermore, the Service cannot force a corporation to incur debt; therefore, accumulating earnings for future business expansion is allowed.
Although the court in Mellbank Corp., 38 BTA 1108 (1938), recognized that the state of the banking business through the Depression required retention of the holding company's earnings to minimize additional capital contributions required to protect the corporation's business investments in operating banks, this reason for accumulating earnings as a defense against assessment of the AET has not been common.
Similarly, if the business only has a few customers, it is more vulnerable to an economic downturn and should be entitled to accumulate additional earnings; this could also justify accumulating earnings for diversification.
A normal operating cycle is defined in the Internal Revenue Manual (IRM) as "the period of time required to convert cash into raw materials, raw materials into inventory of finished goods, finished goods inventory into sales and accounts receivable, and accounts receivable into cash."(12) The need for working capital is the limain reason" for accumulating earnings.(13) The IRM states that the "Bardahl formula is 'one test' and is not necessarily applicable to every [Sec.] 531 case; however, the operating cycle approach is a useful tool and should provide a basic facet of working capital considerations."(14)
The accumulated earnings tax essentially is a penalty imposed on corporations for accumulating earnings rather than distributing them to shareholders as dividends.
The main business reason for accumulating earnings is a corporation's need for sufficient working capital.
Even with moderately higher tax rates at retirement, IRA tax-free compounding of interest provides a higher rate of return and better protection from inflation by accumulating
funds at a faster rate for retirement.
Moreover, with the recent detection of amyloid deposits not just in the brain but in many parts of Alzheimer patients' bodies (SN: 9/23/89, p.197), Selkoe proposes that the beta amyloid associated with Alzheimer's may originate somewhere else in the body, with the protein deposits later accumulating in the blood vessels, brain and elsewhere.
Markersbery of the University of Kentucky in Lexington, perhaps researchers should blame the immune system not for overactivity but instead for loading on the job when it ought to be disposing of the accumulating bits of beta amyloid.
Most climate projections for the next century have focused on how accumulating
greenhouse gases will affect the troposphere and the stratosphere, the two layers closest to Earth.
And several presentations at the New Orleans conference relating to drug treatments and heterosexual transmission may add to the rapidly accumulating
data bank, if not to the tumult.