Quaker Oats Co. v. Commissioner
United States Tax Court
Prior to 1938, petitioner had paid some voluntary pensions on a year-to-year basis to a limited number of its retired employees. It did not have any funded group annuity system. In 1938, it entered into group annuity contracts with several insurance companies to provide pensions and annuities for all of its employees in the United States and Canada.
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Prior to 1938, petitioner had paid some voluntary pensions on a year-to-year basis to a limited number of its retired employees. It did not have any funded group annuity system. In 1938, it entered into group annuity contracts with several insurance companies to provide pensions and annuities for all of its employees in the United States and Canada. Under these contracts payments were made as follows: Payment was made in 1938 of a single premium to purchase annuities for retired employees who were receiving voluntary pensions and for employees who would be eligible to retire by December 31,…
1Opinion of the Court
OPINION.
Harron, Judge:
The questions to be decided involve application of the provisions of section 711 (b) (1) (J), 1939 Code.3 Petitioner made payments in its base period years for various retirement benefits. The problem is the classification of these payments under the provisions of section 711 (b) (1) (J), so that adjustments of petitioner’s excess profits net income for each of the base period years may be properly computed.
Section 711 (b) (1) (J) was intended to be, and is, a remedial statute. The legislation of which this section is a part “attempts to provide, both by specific terms…
2Cases cited6 opinions
- Bonwit Teller & Co. v. United StatesSupreme Court of the United States · 1931
- Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
- Arrow-Hart & Hegeman Electric Co. v. CommissionerUnited States Tax Court · 1946
- Frank Shepard Co. v. CommissionerUnited States Tax Court · 1947
- Great American Indem. Co. v. CommissionerUnited States Tax Court · 1952
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Quaker Oats Co. v. CommissionerUnited States Tax Court · 1957