Section 102 of the Internal Revenue Code, as amended, levies an additional or surtax on corporations. Said Section 102 is entitled "Surtax on Corporations Improperly Accumulating Surplus." However, this title is slightly misleading, in that the purpose is the criterion. Section 102 (a) levies the said additional tax upon the net income of every corporation (other than a personal holding company or a foreign personal holding company).
W.E. Norvell Jr.,
Improper Accumulation of Surplus,
1 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vlr/vol1/iss2/3