Legal Opinion

Lukens Steel Co. v. Commissioner

United States Tax Court

Decided August 7, 1969No. Docket No. 4779-66PublishedCited by 4 opinions

Pursuant to a contract executed by petitioner and the union representing most of its employees, negotiated as to its important provisions by representatives of the major steel companies and of the United Steelworkers Union, petitioner, which kept its books on an accrual basis of accounting, agreed to make certain payments to a fund administered by a trust which would provide supplemental unemployment-benefit payments to its employees.

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Pursuant to a contract executed by petitioner and the union representing most of its employees, negotiated as to its important provisions by representatives of the major steel companies and of the United Steelworkers Union, petitioner, which kept its books on an accrual basis of accounting, agreed to make certain payments to a fund administered by a trust which would provide supplemental unemployment-benefit payments to its employees. A part of the payments to the trust was to be made immediately in cash and a part was to be made at some future time as the financial needs of the fund…

1Opinion of the Court

OPINION

Kern, Judge:

In 1956 petitioner Lukens Steel Co. entered into a labor agreement with the United Steelworkers of America, under which, petitioner agreed to establish a supplemental unemployment benefit plan. The purpose of the plan was to provide benefits, in addition to those under State unemployment-benefit programs, to certain of petitioner’s employees who were laid off during periods of reduced production which recur cyclically in the steel industry. The amount of petitioner’s total obligation under the 1956 SUB plan was determined by reference to the labor hours worked by its…

2Cases cited19 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  3. Schulde v. CommissionerSupreme Court of the United States · 1963
  4. E. W. Schuessler and Aline Schuessler v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1956
  5. Oberman Mfg. Co. v. CommissionerUnited States Tax Court · 1967

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3Cited by4 opinions

  1. Reynolds Metals Co. v. CommissionerUnited States Tax Court · 1977
  2. Cyclops Corp. v. United StatesDistrict Court, W.D. Pennsylvania · 1976
  3. Lukens Steel Co. v. CommissionerUnited States Tax Court · 1969
  4. Reynolds Metals Co. v. CommissionerUnited States Tax Court · 1977

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