Legal Opinion

McClintock-Trunkey Co. v. Commissioner

United States Tax Court

Decided November 24, 1952No. Docket No. 33691Published

1. Employer contributions to an exempt pension and profit-sharing trust in excess of the agreement's terms held voluntary and not deductible under section 23 (p) (1) (C) or (D), Internal Revenue Code. Wooster Rubber Co., 14 T. C. 1192, followed. 2. Dues paid to associations whose activities are devoted in substantial part to lobbying and propaganda purposes held not deductible as ordinary and necessary expenses.

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1. Employer contributions to an exempt pension and profit-sharing trust in excess of the agreement's terms held voluntary and not deductible under section 23 (p) (1) (C) or (D), Internal Revenue Code. Wooster Rubber Co., 14 T. C. 1192, followed. 2. Dues paid to associations whose activities are devoted in substantial part to lobbying and propaganda purposes held not deductible as ordinary and necessary expenses. Section 23 (q) (2), Internal Revenue Code. 3. Additions to petitioner's reserve for bad debts held, on facts, properly disallowed by respondent.

1Opinion of the Court

The McClintock-Trunkey Co., Petitioner, v. Commissioner of Internal Revenue, Respondent

McClintock-Trunkey Co. v. Commissioner

Docket No. 33691

United States Tax Court

19 T.C. 297; 1952 U.S. Tax Ct. LEXIS 37;

November 24, 1952, Promulgated

Decision will be entered for the respondent.

1. Employer contributions to an exempt pension and profit-sharing trust in excess of the agreement's terms held voluntary and not deductible under section 23 (p) (1) (C) or (D), Internal Revenue Code. Wooster Rubber Co., 14 T. C. 1192, followed.

2. Dues paid to associations whose activities are devoted in substantial…

2Cases cited8 opinions

  1. Textile Mills Securities Corp. v. CommissionerSupreme Court of the United States · 1941
  2. Black Motor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
  3. First-Mechanics Nat. Bank v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1940
  4. Wooster Rubber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951
  5. Roberts Dairy Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1952

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