E. R. Wagner Mfg. Co. v. Commissioner
United States Tax Court
Profit-Sharing Plan -- Exempt Trust -- Deduction for Contribution -- Reduction of Percentage Shared -- Section 23 (p) (1) (C) -- Section 165 (a). -- Exemption of trust and employer's right to deduction for annual contributions continued despite reduction in percentage of profits to be shared through contributions.
1Opinion of the Court
OPINION.
Muedock, Judge:
The Commissioner determined deficiencies as follows:
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The only issue is whether the petitioner is entitled to deduct for each of the four years the amount which it contributed for that year to its employees’ profit-sharing trust. The facts have been stipulated.'
The returns for the taxable years were filed with the collector of internal revenue for the district of Wisconsin.
Section 23 (p) (1) (C) allows deductions for contributions of an employer to an employees’ trust, exempt under section 165 (a), if paid by the employer under a profit-sharing plan, in an…
2Cases cited2 opinions
- Lincoln Electric Co. Employees' Profit-Sharing Trust v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951
- Lincoln Electric Co. Employees' Profit-Sharing Trust v. CommissionerUnited States Tax Court · 1950
3Cited by4 opinions
- Estate of Davis v. CommissionerUnited States Tax Court · 1954
- Davis v. CommissionerUnited States Tax Court · 1954
- Davis v. CommissionerUnited States Tax Court · 1954
- E. R. Wagner Mfg. Co. v. CommissionerUnited States Tax Court · 1952