The accumulated earnings tax is imposed only when the corporation is "formed or availed of for the purpose of avoiding the income tax." Does tax avoidance have to occur at the corporate or the shareholder level for the accumulated earnings tax to be imposed? Does tax avoidance have to be the sole motive for earnings accumulation before such imposition?

The accumulated earnings tax is imposed only when the corporation is "formed or availed of for the purpose of avoiding the income tax " Does tax avoidance have to occur at the corporate or the shareholder level for the accumulated earnings tax to be imposed? Does tax avoidance have to be the sole motive for earnings accumulation before such imposition