Ryan School Retirement Trust v. Commissioner
United States Tax Court
On October 31, 1944, the Ryan School established a pension trust covering 110 rank and file employees and 5 officers. The Commissioner approved the plan and ruled that the trust was tax exempt under section 165 (a) of the 1939 Code. Of initial contributions to the plan, 8.4 per cent was credited to the 5 officers and 91.6 per cent to the other employees.
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On October 31, 1944, the Ryan School established a pension trust covering 110 rank and file employees and 5 officers. The Commissioner approved the plan and ruled that the trust was tax exempt under section 165 (a) of the 1939 Code. Of initial contributions to the plan, 8.4 per cent was credited to the 5 officers and 91.6 per cent to the other employees. On October 31, 1951, because of terminations due to adverse business conditions, the only participants remaining in the plan were the 5 officers, 3 rank and file employees who had been continuous participants, and 2 other employees. The plan…
1Opinion of the Court
OPINION.
T?.Tmn3 Judge:
This proceeding involves deficiences in income tax determined against the Ryan School Retirement Trust as follows:
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The only issue is whether the Ryan School Retirement Trust was a pension trust exempt from taxation under section 165 (a) of the Internal Revenue Code of 1939, during such years.
All of the facts were stipulated, are so found, and are incorporated herein by this reference.
The Ryan Aeronautical Company (hereinafter referred to as the Company) was incorporated under the laws of the State of California on June 5,1931. A wholly owned subsidiary, the…
2Cases cited1 opinion
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