Legal Opinion

American Stores Co. v. Commissioner

United States Tax Court

Decided March 31, 1997No. Docket No. 19182-94Published

P made contractually required monthly contributions to 39 multiemployer pension plans. P also provided vacation pay benefits to its employees under various plans.

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P made contractually required monthly contributions to 39 multiemployer pension plans. P also provided vacation pay benefits to its employees under various plans. For its TYE Jan. 31, 1987 (8701), P obtained an extension of the time within which to file its U.S. consolidated corporate income tax return to Oct. 15, 1987. For its TYE Jan. 30, 1988 (8801), P obtained an extension of the time within which to file its U.S. consolidated corporate income tax return to Oct. 17, 1988. On its return for TYE 8801 P deducted, in addition to the 12 monthly contributions based on units of service worked…

1Opinion of the Court

AMERICAN STORES COMPANY AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

American Stores Co. v. Commissioner

Docket No. 19182-94

United States Tax Court

108 T.C. 178; 1997 U.S. Tax Ct. LEXIS 9; 108 T.C. No. 12; 20 Employee Benefits Cas. (BNA) 2721;

March 31, 1997, Filed

Decision will be entered under Rule 155.

P made contractually required monthly contributions to 39 multiemployer pension plans. P also provided vacation pay benefits to its employees under various plans. For its TYE Jan. 31, 1987 (8701), P obtained an extension of the time within which to file its U.S.…

2Cases cited10 opinions

  1. Reisman v. CaplinSupreme Court of the United States · 1964
  2. United States v. FlannerySupreme Court of the United States · 1925
  3. Commissioner v. KorellSupreme Court of the United States · 1950
  4. Oberman Mfg. Co. v. CommissionerUnited States Tax Court · 1967
  5. E. H. Sheldon & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954

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