The accumulated earnings tax is imposed only when the corporation is formed or availed of for the

Question:

The accumulated earnings tax is imposed only when the 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?
Corporation
A Corporation is a legal form of business that is separate from its owner. In other words, a corporation is a business or organization formed by a group of people, and its right and liabilities separate from those of the individuals involved. It may...