Studmuffin, Inc. was in the business of designing and producing athletic wear. The owners of Studmuffin wanted to enter related fields and expand their operations. They believed that the manufacturing and installation of muscle$-$building equipment would be a profitable area. The officers of Studmuffin felt they had the business contacts to do well in this field, but they needed additional expertise in the design and manufacture of equipment. They decided that the best way to approach this type of expansion would be to acquire an existing company, so that the assembly process and skilled workers would be immediately available to them.

The First National Bank of Red Lick was willing to lend Studmuffin the amount required. A target company was located: TwiceAs$-$Nice Equipment of Texarkana. The terms of the note with the bank were as follows:

The face amount of the note was $$10,000,000.$

Interest was stated at the rate of $10$ percent, simple interest beginning January $1,2013.$

The note was for $10$ years.

At all times during the period in question, $2013$ through $2023,$ Studmuffin had accumulated funds at least equivalent to the outstanding balance of the long$-$term indebtedness. The officers of Studmuffin knew that at any time they could have paid off this loan balance. At the same time, however, Studmuffin was earning more than the $10$ percent charged by the bank and so had no inducement to do so$.$ For instance, the financial vice$-$president for Studmuffin reported that the average return on invested capital for the company was almost $17$ percent.

In $2023,$ the Internal Revenue Service audited Studmuffin. The examining agent assessed an accumulated earnings tax against Studmuffin. Studmuffin consults you in the hope of avoiding the accumulated earnings tax assessment. How would you advise on this question?