Hydro Molding Co. v. Commissioner
United States Tax Court
Accrual basis corporation is not entitled to a deduction for contribution to a profit-sharing trust fund for the calendar year 1957 where payment thereto was not made prior to the time prescribed by law for filing its income tax return for that year and no extension of time for filing the return was sought or obtained.
1Opinion of the Court
Scott, Judge:
Respondent determined a deficiency in petitioner’s income tax for the calendar year 1957 in the amount of $9,221.42.
The only issue for decision is whether petitioner is entitled to a deduction in the year 1957 in the amount of $17,733.51 as a contribution to a profit-sharing plan.
FINDINGS OF FACT.
Some of the facts have been stipulated and are found accordingly.
Petitioner is a corporation, incorporated under the laws of the State of New York on January 4, 1955. It filed its corporate income tax return for the calendar year 1957 with the district director of internal revenue at…
2Cases cited3 opinions
- Sachs v. Commissioner of Internal Revenue. Slaymaker Lock Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
- Radom & Neidorff, Inc. v. United StatesUnited States Court of Claims · 1960
- Campbell Chain Co. v. CommissionerUnited States Tax Court · 1951
3Cited by5 opinions
- Gillis v. CommissionerUnited States Tax Court · 1974
- Dillard Paper Co. v. CommissionerUnited States Tax Court · 1964
- Dillard Paper Co. v. CommissionerUnited States Tax Court · 1964
- Gillis v. CommissionerUnited States Tax Court · 1974
- Hydro Molding Co. v. CommissionerUnited States Tax Court · 1962