§ 532. Corporations subject to accumulated earnings tax
(a)
General rule
The accumulated earnings tax imposed by section
531 shall apply to every corporation (other than those described in subsection (b)) formed or availed of for the purpose of avoiding the income tax with respect to its shareholders or the shareholders of any other corporation, by permitting earnings and profits to accumulate instead of being divided or distributed.
(c)
Application determined without regard to number of shareholders
The application of this part to a corporation shall be determined without regard to the number of shareholders of such corporation.