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Although the terms of the Penn Mutual loan were somewhat less stringent than those of the bank loans, nevertheless, petitioner found them confining. (Experimental). The yeast I used fermented the mead to dry and still had a much higher alcohol tolerance. Mead's was founded in 1918 by J.H. We use cookies to ensure that we give you the best experience on our website. Sick bucks a week. Petitioner has failed to meet its burden of proof on this ultimate issue. The boycott gave Moore a complete monopoly of the bread business in Santa Rosa. The busy boulevard in 1965, six lanes wide with abundant centered street lights. The consolidated accumulated earnings credit is. When the war was over I returned to college and, despite the GI bill, the need for extra income arose. Obverse reads: "Mead's Fine Bread" The encasement has wrapper lines on the right end to give it a 3-D look. Neither Ed V. Mead nor any other officer of Angus or petitioner devoted any of his time to the affairs of Angus. Aside from the tenant farmer, Angus had no employee during the years in issue. 1055 (1927), affd. Get free access to the complete judgment in MOORE v. MEAD'S FINE BREAD CO on CaseMine. Petitioner contends that for purposes of computing this credit it is permitted to consider the needs of Angus, even though Angus may not have been actually engaged in any business, in determining the reasonable needs of the business of the group. Researchers, educators, and students may find this photograph useful in their work. The Court said, "Congress by the Clayton Act and Robinson-Patman Act barred the use of interstate business to destroy local . At the time petitioner acquired the stock of Angus in connection with the May, 1, 1955, reorganization, petitioner's management decided to discontinue Angus' cattle raising activities because they constituted too great a drain on petitioner's working capital. Mr. Justice DOUGLAS delivered the opinion of the Court. Newspaper Page Text PITTSIIIJR.GR,GAZE. University of North Texas Libraries, The Portal to Texas History, https://texashistory.unt.edu; The Premanands were fined a total of about $60,670 (38,000) plus council costs and a banning order that effectively prevents them from ever managing a food business again. Do they still sing The Old Rugged Cross? 4615_1 No tags have been applied so far. Fred, of course, was gone, and during the war my friend Doc Mead had become not only a big shot in the bakery business but a millionaire. Thus, to the extent petitioner was able to make these advances to Angus, such funds were not required for use in petitioner's business. Jos R. Ralat is Texas Monthlys taco editor, writing about tacos and Mexican food. Serger & Overlock Machine Accessories. 6, 1929), certiorari denied 280 U.S. 588 (1929); John A. Nelson Co. v. Commissioner [35-1 USTC 9164], 75 F.2d 696, 697 (C. A. Section 1.1502-31(a)(19)(i), Income Tax Regs. Although Meads Quartet never reached the point of commanding a fee for public performances, it was in demand for revivals, special appearances, and funerals. In 1957 and 1958 it purchased additional stock in this bank at a cost of $16,000 and $38,930. The Secretary of the Navy died, and the captain ordered a memorial servicewith one days assembly time. These structures were, therefore, suitable solely for baking purposes. Bakery & Bread Shop All Sliced Bread . . The announcers wife played the piano, and he sang baritone. Petitioner sold its stock in First State Bank of Amarillo on August 20, 1959, for $251,650, realizing a gain of $138,430, and used a portion of these proceeds to pay these amounts. Featuring thousands of newspapers, photographs, sound recordings, technical drawings, and much more, this diverse collection tells the story of Texas through the preservation and exhibition of valuable resources. The encasement is approximately 2 inches wide by 1 at its tallest point. Similarly, petitioner carries on its books a liability in the amount of $100,716 to Ed V. Mead for stock he transferred to petitioner on September 14, 1961, in Mead Co., Inc. During the years in issue petitioner owned 98 percent of the outstanding stock in Mead's Angus Mesa, Inc. (hereinafter referred to as Angus). February 2023 Reader Quiz: What Did You Learn? We had some touching arrangements for the lovelier songsI broke up many a time as we hummed under a tenor solo (Sweet hour of prayer, sweet hour of prayer,/Thy wings shall my petition bear) or sang What a Friend We Have in Jesus., So many of those old hymns were laboring songs: Work for the Night Is Coming, To the work! All were visually striking. Donald L. Wilson and Kenneth G. Tarlton, for the petitioner. When we wanted to bring em to their knees, we did The Old Rugged Cross. We sang the first verse in close harmony, with just a little piano (On a hill far away stood an old rugged cross). Mr. Lane (1924-2000), an Army veteran and graduate of Texas A&M University, joined the Campbell Taggart accounting department in 1947. Mead and his four sons. In 1959, he merged that business with Campbell Taggart, and a few years later, he became chairman and CEO of the company. Varieties|Coin Links|About| [Mead's Fine Bread Company], [4 USTC 1299] 72 F.2d 67 (C. A. D. C. 1934); cf. Cf. The capital stock and earned surplus of the predecessor corporations before the May 1, 1955, reorganization and that of petitioner immediately subsequent thereto, were as follows: Petitioner's average cash balance for the four weeks ended July 21, 1955, was $150,293.76.2 Petitioner found this amount of cash insufficient for purposes of conducting its business. He was elected president in 1982. We do not agree with any of petitioner's contentions relating to its advances to Angus. crediting McMurry University Library. Mead's Frozen Foods, Inc., was organized to permit petitioner to enter into this line of business without violating the restrictive covenants of the Penn Mutual loan. Big Jim directed us, and I wrote the scripts, which consisted of brief spoken introductions to the hymns, things like From the little church just around the corner of your heart comes . Mead's Fine Bread Co., 348 U.S. 115, 75 S.Ct. The executives invested substantially in new technology to open new markets, specifically taking pan variety bread to national distribution. These corporations purchase their flour and bread wrappers as a unit. We've created an Next, we have the Lalvin EC-1118, a very strong yeast that has an ABV tolerance of up to 18 percent ABV. Mrs. Claude M., Baird, Texas.. MEAD'S FINE BREAD COMPANY, a Corporation. Meads Fine Bread Co., his competitor, engaged in an interstate business. Moore v. Mead's Fine Bread Co., 348 U.S. 115 (1955) - Free download as (.court), PDF File (.pdf), Text File (.txt) or read online for free. Helpful links in machine-readable formats. Here are some suggestions for what to do next. Bins It tasted a bit old. It maintains its books and records and files its Federal income tax returns on the basis of a fiscal year ended April 30. These controls are experimental and have not yet been optimized for user experience. For the Tucson plant, it had estimated construction cost of $100,000 and costs for equipping the plant of $250,000. Some of those which influenced petitioner's management to retain its earnings in order to be able to produce or utilize these innovations were: (1) "Brown and Serve" rolls; (2) "diet bread"; (3) "round bread"; and (4) the use of plastic "end seals" in wrapping loaves of bread. When the case was first here, Moore v. Mead Service Co., 10 Cir., 184 F.2d 338, on appeal from a judgment of the trial court dismissing the . Motor Fuel Carriers, Inc. v. United States [63-2 USTC 9697], 322 F.2d 576 (C. A. For partners and peer institutions seeking information about Many cheeses have been coated in ash to enhance flavor and add a smoky undertone, but this is the first time that charcoal has been fully incorporated into a cheese. Frankly, being a hymn singer didnt cut much rank in the U.S. Navy. The acquisition of the 14 plants by the predecessor corporations between 1946 and May 1, 1955, had depleted their earnings and adversely affected their ability to add to and replace equipment during the period from 1946 to 1955. Cf. Once, a dozen years ago, a bunch of us even made an LP of some old gospel swingers. Thus, for example, in March 1955, shortly before the reorganization occurred, one of the predecessor corporations acquired a large bakery plant in Oklahoma City, Oklahoma. This truly unique cheese is made with charcoal from the Featherstone mines in Yorkshire mixed with a wonderfully creamy mature wax coated cheddar. Click the citation to see the full text of the cited case. View a full description of this photograph. A naturally leavened artisan fruited bread with sweet bites of peach and semi-candied apricot complemented by the fragrance of lavender. The requests poured in, sometimes with the titles spelled phonetically: And please play Father Alone, first chance you get or Dead Meads Quartet: Will you please sing Blessed Insurance for my sister who has just lost her husband. To the work! It also distributes school and office supplies made by Mead and other companies and has . 4615. PO Box 130967, Tyler, TX 75713. consistently emphasize the unreasonably low prices and the predatory intent of the defendants." Side: Shortly after its incorporation on April 27, 1955, petitioner, in a tax-free reorganization, acquired the assets and assumed the liabilities of the following corporations, which were then dissolved: (These corporations will hereinafter sometimes be referred to as the predecessor corporations.) These buildings were constructed by Mead Industries, Inc., according to petitioner's exact specifications. Citations are also linked in the body of the Featured Case. Moreover, although petitioner's four-week cash balance for its fiscal year ended April 30, 1956, was $360,283.37, the major portion of this amount consisted of loan proceeds, namely, $281,000 borrowed from The Penn Mutual Life Insurance Company on February 1, 1956. He upped my wages to $7.50. Eaten claims that he Is a paralvtlc and that on Feb. 22 he fell and broke his collar bone and that on the 2lth of the samo month he went into the saloon to dis pose of some of his stock of matches. True, I had been given a work concession by Abilene Christian College, where I was enrolled, but it was for only $20, which not only didnt cover tuition but didnt cover food, shelter, clothing, or bus fare. Whats Up With All the Kangaroos on the Loose in Texas. William Ernest Seatree [Dec. 7413], 25 B. T. A. Research the case of Mead's Fine Bread Co. v. Moore, from the Tenth Circuit, 12-11-1953. On March 21, 1961, respondent, by registered mail and pursuant to section 534, notified petitioner that respondent intended to issue a deficiency notice for the taxable years ended April 30, 1956, through April 30, 1958, based on section 531. The company's mailing . 121. 'I came back, I played a . Mead Service Company and Mead's Fine Bread Company, hereinafter referred to as Mead, were confronted with a boycott at Santa Rosa, New Mexico, which entirely deprived them of a market for their bread at that point. And that was no legend. Their families describe them as proud Texans and leaders in their home and church communities. On the second verse Jimmy did a solo over our humming (Oh, that old rugged cross so despised by the world,/Has a wondrous attraction for me), and the last verse we did a cappella, phrasing it tightly, bring the piano back in for the chorus. Decided Dec. 6, 1954. The estimated average cost of purchasing and installing the necessary equipment was $150,000 per plant. Throughout its entire existence, petitioner has experienced great diffculty in obtaining adequate credit and financing. Every hymn was handled like a symphonyand I dont mean to imply that the horn, drum, and saxes were the only instruments; I didnt dare turn and stare, but I know I heard a banjo, strings, at least two cornets (because they tried to harmonize), something mysterious that a GI had brought back from Japan, and a set of snares rigged for marching. During this same period, Ed V. Mead filed joint returns with his wife, Elizabeth Mead. sections 533(b) and 535(c)(1) and (3); and section 1.1502-3, Income Tax Regs. It is our opinion that, in the computation of the consolidated accumulated earnings credit under section 1.1502-31(a)(19)(i) of the Income Tax Regulations, only the reasonable needs of the operating companies included in the group may be considered. they all market their bread under the name "Mead's Fine Bread" and promote the product through a common advertising program. Check out our Resources for Educators Site! Petitioner made offers on 10 of these plants. Messrs. Lynell G. Skarda, Dee C. Blythe, Clovis, N.M., for petitioner. Mead's Fine Bread Co. v. Moore, Court Case No. Rands, Inc. [Dec. 9491], 34 B. T. A. MEADOWVIEW POOL CO; MEADS STEPHEN OIL CO CO; MEAD-RAYMOND CORPORATION. Petitioner did not submit a statement of grounds, as permitted under section 534(c). Service is great. Doc admitted he had a tin ear, but since he paid the freight, his recommendation wrote the ticket. In 1955, petitioner had 1,037 employees. And what will be remembered of the high-flying anthems and hundred-voice-choir pieces of today? I tell you, not a dry eye in the house. photograph Therefore, we conclude that the advances on open account to Angus during petitioner's taxable years 1956 through 1958 represent unreasonable accumulations of surplus. During the years in issue, the course pursued by petitioner with regard to expansion remained the same. We've been unable to identify the creator(s) of this photograph. MEAD'S FINE BREAD COMPANY, a Corporation: Docket Number: No. Meads Quartet didnt need all that support system. The following is a consolidated balance sheet reflecting, on a consolidated basis, the assets and liabilities of petitioner and its subsidiary, Angus, during the years before this Court. We ordered the grilled artichokes, the lamb tart, the pozole negro, and the ricotta cavatelli. [Mead's Fine Bread Company], Doc Mead owned Meads Fine Bread bakery, and Meads Quartet sang on KRBC for fifteen minutes at noon on weekdays. By April 30, 1957, these increased to $250,000 and to $421,000 as of April 30, 1958. WHEN UPON LIFES BILLOWS you are tempest tossed, When you are discouraged, thinking all is lost . Angus sustained substantial net operating losses from the year petitioner acquired it until it was disposed of in 1960. Winter Park Chamber Immersive Art Exhibit Field Trip happening at Mead Botanical Garden, 1300 South Denning Drive, Winter Park, United States on Thu Mar 30 2023 at 11:30 am to 01:30 pm . Co. v. United States [47-1 USTC 9280], 72 F.Supp. It had been contemplated that petitioner would acquire direct control of this business when it was free of the conditions imposed by said loan agreement. The common round shape is well known in several diameters. One of the first meads ever produced and sold by Enlightenment Wines Meadery . The best restaurants in town were located along "The Main Street of America" in the '60s. ; Raymond I. Smith, Inc. [Dec. 23,812], 33 T.C. To learn more about cookies and how ASB uses them please visit our Privacy Policy page. Lalvin EC-1118. These corporations maintain plants at Lubbock and Big Spring, Texas, and at Hobbs, Roswell, and Clovis, New Mexico. They had a competitor in Santa Rosa, Texas, and Mead's cut the price of their bread from 14 to 7. He appointed me to reorganize the quartet, took out half a page in the newspaper to announce itand paid us $15 a week. The company used this jingle: A paper hat used by Mead's employees - "That's What I Said" "Mead's Fine Bread and Potato Chips, too" At the top is a nail file given away as a promotional item. Petitioner's average four week cash balances for the fiscal year ended April 30, 1956, was $360,283.37. Reference to our Findings of Fact indicates that petitioner has clearly demonstrated that in each of the above-described instances it used its funds for legitimate business reasons and that it has rebutted any inference of unreasonable accumulations arising from such transactions. Substantially all of the expenses claimed by Angus represented deductions for interest, depreciation, taxes, and insurance. Click on the case name to see the full text of the citing case. from atop St. Anthony's Hospital about 1960. These loans proved unduly restrictive. Petitioner had in its possession standard architectural plans which it expected to use in erecting these bakeries. large collection of U.S. government documents. In part, these time deposits were held as to reserve for the contingent tax liability. . He was born February 7, 1932 to N.B. This photograph is part of the following collections of related materials. 9, 1954); cf. Thus, in 1956 petitioner began to set aside a portion of its earnings to effect these plans. about this topic here. That girl had a better knack for peacemaking than war, and even a hound like Radagon could be coaxed away from his aggressive mantras. The cattle were sold at auction in October 1955. Unique identifying numbers for this photograph in the Portal or other systems. . Follow the links below to find similar items on the Portal. Ed V. Mead repaid the amount loaned to him by petitioner during its fiscal year ended April 30, 1958. All Rights Reserved, National Bakery Associations and Resources, Baker Equipment Manufacturers and Allieds. December 6, 1954, the United States Supreme Court found that Mead's Fine Bread was in violation 2 of the Clayton Act and 3 of the Robinson-Patman Act this was a Landmark case in interstate competition. After overseeing the merger of Campbell Taggart with Anheuser Busch, Mr. Mead retired in 1983. Commissioner v. Ehrhart [36-1 USTC 9142], 82 F.2d 338 (C. A. As a direct result of these negotiations, petitioner did, in fact, purchase 4 of these plants, as follows: In addition to its plans for purchasing additional bakery plants during the years herein involved, petitioner also had specific plans for constructing new plants in Tucson, Arizona, and Ada, Oklahoma. In connection with its acquistion on May 1, 1955, of the four predecessor corporations, petitioner acquired the Angus stock, which had previously been owned by one of the predecessor corporations (hereinafter referred to as El Paso). Deering v. Blair [1928 CCH D-8065], 23 F.2d 975 (C. A. D. C. 1928); Thacher v. Lowe [1 USTC 70], 288 F. 994 (S. D. N. Y. In order to keep up with its competition, rising costs and the increasing population of the areas it served, petitioner was forced to expend considerable sums for replacing old equipment and purchasing new equipment. This is an appeal from a verdict and judgment in favor of the plaintiff-appellee in an action for treble damages under the Robinson-Patman Amendment to the Clayton Act, 15 U.S.C.A. and Florence VanHoozer in the Bethel community east of Lawton, and was one of four kids. Of the 711 students enrolled in the school, 4 had their own cars. Immediately prior to petitioner's absorption of the four predecessor corporations, Angus possessed a herd of 100 breeding cows and a one-half interest in a prize stud bull. Rich in sea salt and amino acids, our formula instantly lifts limp hair from the roots, while Fo-Ti and hydrolyzed rice protein improve hair growth and density in the long term. Get free access to the complete judgment in MEAD'S FINE BREAD CO. v. MOORE on CaseMine. It has been viewed 1144 times, with 31 in the last month. New Mexico company code: 268904. No. 3. After I added the thyme, ham and sour cream, my husband declared, "This is it!". This is an automated process which produces bread of a better texture and quality at a cost of approximately 10 to 15 percent less than the conventional methods. was provided by the McMurry University Library 1954) Annotate this Case US Court of Appeals for the Tenth Circuit - 208 F.2d 777 (10th Cir. Eternal Father, strong to save, Whose arm hath bound the restless wave, Who biddst the mighty ocean deep Its own appointed limits keep, O, hear us when we cry to Thee For those in peril on the sea! The Hymn of the U.S. Navy. a digital repository hosted by the Abilene Library Consortium Also in conjunction with the "Critical Mass" exhibition at the Mead Art Museum, the Frost Library presents FluxusFluxusFluxus, an exhibition drawn from its extensive collection of Fluxus material. Mr. Edward W. Napier, Lubbock, Tex., for respondent. 757, 764-765 (1963), on appeal (C. A. . 90 (1954), affd. If the answer to this issue is in the affirmative, we must determine for each year in question what part of petitioner's earnings and profits, if any, has been retained for the reasonable needs of its business. 69, 80-82 (1958). I did hold membership in the Bluejacket Choir, but there were too many opera singers and famous vocalists for a Texas fundamentalist to hang on very long. However, there is one factor mentioned by respondent which bears even more intensive scrutiny, namely, the advances made by petitioner on open account to its subsidiary, Angus, during the years in question.9 Cf. Earnings and profits of the first corporation put into the second corporation through the purchase of stock or securities or otherwise, may, if a subsidiary relationship is established, constitute employment of the earnings and profits in its own business. The Mead family has been engaged in the business of manufacturing and distributing bread on a wholesale basis in the southwestern part of the United States since at least 1938. Funerals always brought out the worst in us. June 5, 1946 Mead's Fine Bread Company of Big Spring, Big Spring, Texas Oct. 7, 1946 Mead's Fine Bread Company of El Paso, El Paso, Texas Mar. Respondent sells bread in Farwell, Texas, a town which it serves with a bread truck operating out of Clovis, New Mexico. Leagle.com reserves the right to edit or remove comments but is under no obligation to do so, or to explain individual moderation decisions. But it wasnt the same. Development costs for the new route, including additional consumption of supervisor time and more stale, unsold bread to be picked up from the stores on the route, result in losses of approximately an additional $5,000 per route for the first year of operation. The thing I did not enjoy was the bread. They all market their bread under the name 'Mead's Fine Bread' and promote the product through a common advertising program. sub nom. We also provide No. United States Court of Appeals Tenth Circuit. As previously indicated, during the years in issue, petitioner steadily expanded its activities in the bakery business. Petitioner's management had estimated during the years in issue that trade accounts receivable would increase between 20 and 25 percent per year. Rehearing Denied Jan. 31, 1955. The sponsor was a bakery; the subject was the Bread of Life. per curiam [56-1 USTC 9139] 227 F.2d 779 (C. A. They alleged that Mead's Fine Bread sold bread both locally and interstate, and, in the course of such business, maintained prices in interstate transactions but cut prices in intrastate transactions in petitioner's locality, thus driving petitioner out of business. Sign into add some. section 1.537-2(c)(1), Income Tax Regs.) . Thereafter, Angus' sole activity, aside from renting the home on its farm to Ed V. Mead and selling off unneeded equipment, was to lease, on a share crop basis, a portion of its land for the cultivation of hay. Decided Dec. 6, 1954. Notes [ edit] Telephone to Glory, oh, what joy divine! Lane were chairman, CEO and president of The Earthgrains Co. (previously Campbell Taggart, Inc. and today part of Bimbo Bakeries USA), Dallas, Texas. 334. Public Company Incorporated: 1930 Employees: 21,600 Sales: $4.77 billion Stock Exchanges: New York Midwest Pacific The Mead Corporation is one of the world ' s largest manufacturers of paper and related products. Your support aids students of all ages, rural communities, These corporations purchase their flour and bread wrappers as a unit. Petitioner during the years involved herein also had definite plans for diversification into the business of manufacturing and distributing potato chips and frozen baked products. One such factor is the rapid growth of the four predecessor corporations between October 1946 and May 1, 1955, whereby they acquired 14 additional plants and doubled their number of employees. 148, 99 L.Ed. We sang the Navy hymn while the chaplain intoned Crossing the Bar, and it was so successful that station WCAU recorded it and played it several times that evening. This loan also prohibited petitioner from acquiring any new corporations or assets by merger, or in return for the issuance of its stock. The proposed tax deficiencies were finally determined to be $149,393.66, per Tax Court decision of November 10, 1959. In 1978, the Although petitioner experienced no strike or other such work stoppage in any of its plants between 1950 and 1959, losses due to such disputes were a reasonable factor for petitioner's management to consider. In 1958, petitioner also acquired common stock in Citizens National Bank, Abilene, Texas, at a cost of $11,280.4 During the years in issue petitioner maintained a portion of its assets in the form of time deposits. The cases linked on your profile facilitate Casemine's artificial intelligence engine in recommending you to potential clients who might be interested in availing your services for similar . But Doc remained approachable, the same sweet, tin-eared guy. Thus, to the extent the stipulation of facts in this proceeding provides that Angus was engaged in the agricultural and livestock business during the years in issue, it is hereby set aside. Petitioner's average cash balance for the four weeks ended March 1, 1956, excluding the proceeds of the Penn Mutual loan, was $40,733.86. ; Electric Regulator Corporation [Dec. 26,236], 40 T.C. 1949 Mead's Fine Bread Unusual Loaf Shape Encased Coin Wheat Penny One C 1949 Meads Fine Bread Encased Cent - Loaf Of Bread Shape -Unusual 1949 D Encased Cent - Wonder Bread - Penny For Penny Your Best Food Buy 1949 Mead's Fine Bread Figural Loaf Bakery Good Luck Penny Encased Cent 1949 Mead's Fine Bread Encased Cent Shaped Like Loaf Of Bread per curiam [1929 CCH D-9307] 34 F.2d 1022 (C. A. My first check as a radio gospel singer on KRBC in Abilene was for $6 and was signed by Elliott Roosevelt. At all times relevant hereto, it was contemplated that petitioner would acquire the stock of Mead Co., Inc., after it had either paid or refinanced the loan from Penn Mutual. God Be With You Closing theme of Meads Quartet. MEAD'S FINE BREAD COMPANY (trading name, 1949-11-08 - 1960-04-29) Music has always had more effect on my emotions than the spoken word. However, one of the most popular and unusual shapes to collect is the bread loaf shape. Once, in Philadelphia, I enjoyed a comeback. Mead's Fine Bread Company filed as a Domestic For-Profit Corporation in the State of Texas and is no longer active. I night-managed a drive-in cafe right up to the week before graduation. UNT's history and scholarship, library special collections, plus a about this topic here. Mr. Edward W. Napier, Lubbock, Tex., for respondent. Zoom and Pan the map as needed. K-12 lesson plans, tools, and other help for history teachers. Listed below are the cases that are cited in this Featured Case. . Log In. The cost of these additions exceeded depreciation allowed during this period by approximately $170,000. A week later I was shipped out to the U.S. Marine Corps, and for two years the only hymn I sang was The Marines Hymn (First to fight for right and freedom/And to keep our honor clean). Mead's Fine Bread Co., 348 U. S. 115 (1954), a case based in part on 3, recognized the applicability of the Robinson-Patman Act to conduct quite similar to that with which National Dairy and Wise are charged here. Since petitioner did not submit a statement of grounds in response to the notification sent by respondent pursuant to section 534(b), petitioner must bear the burden of proving that all or any part of its earnings and profits has not been permitted to accumulate beyond the reasonable needs of its business.