Lord v. Commissioner
United States Tax Court
In 1937 Phillips H. Lord, Inc., all of whose voting stock was owned by Phillips H. Lord, paid to the trustees of a pension trust which it had created on December 23, 1937, $ 14,769 for the purpose of the acquisition by the pension trust of annuity contracts from the Equitable Life Assurance Society.
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In 1937 Phillips H. Lord, Inc., all of whose voting stock was owned by Phillips H. Lord, paid to the trustees of a pension trust which it had created on December 23, 1937, $ 14,769 for the purpose of the acquisition by the pension trust of annuity contracts from the Equitable Life Assurance Society. The president and treasurer and highest paid employee was Phillips H. Lord, for whom the trustees purchased the same kind of annuity contract as was purchased for other employees. Held, that the corporation is entitled to deduct from its gross income the $ 14,769 paid to the trustees of the…
1Opinion of the Court
OPINION.
Smith, Judge:
We consider the first question whether Phillips H. Lord, Inc., is entitled to deduct from its gross income of 1937 $14,769 paid to the Phillips H. Lord, Inc., pension trust. In the deficiency notice the respondent disallowed the deduction “for the reason that it is not deductible under any provision of the Revenue Act of 1936, as amended.” In his brief he relies upon the following points in support of his claim that the amount is not a legal deduction:(a) Phillips H. Lord was the petitioner corporation’s President and Treasurer, as well as one of its three Directors.(b)…
2Cited by30 opinions
- Jones v. CommissionerUnited States Tax Court · 1943
- Wesley Heat Treating Co. v. CommissionerUnited States Tax Court · 1958
- William M. Bailey Co. v. CommissionerUnited States Tax Court · 1950
- Hubbell v. CommissionerCourt of Appeals for the Sixth Circuit · 1945
- Moore v. CommissionerUnited States Tax Court · 1946
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