Saalfield Pub. Co. v. Commissioner
United States Tax Court
Deductions -- Pension Trust -- Section 23 (p) (1) (A), I. R. C. -- Held that, under 23 (p) (1) (A) (i) and (ii), the taxpayer is entitled to deduct in full the amount paid to an employees' pension trust which is actuarially necessary to provide with respect to all employees under the trust the remaining unfunded cost of their past and current service credits distributed as a level amount over the remaining future service of each such employee, even though such amount exceeds…
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Deductions -- Pension Trust -- Section 23 (p) (1) (A), I. R. C. -- Held that, under 23 (p) (1) (A) (i) and (ii), the taxpayer is entitled to deduct in full the amount paid to an employees' pension trust which is actuarially necessary to provide with respect to all employees under the trust the remaining unfunded cost of their past and current service credits distributed as a level amount over the remaining future service of each such employee, even though such amount exceeds the deduction allowable under 23 (p) (1) (A) (iii); held, further, section 29.23 (p)-6 of Regulations 111 so applied as…
1Opinion of the Court
OPINION.
Murdock, Judge-.
The Commissioner determined deficiencies in income tax, declared value excess profits tax, and excess profits tax for 1943 in the total amount of $5,805.04. The separate deficiencies have not been proved. The petitioner on its returns claimed a deduction of $37,471.41 representing its contribution to a pension trust. The Commissioner allowed $30,938.17.. The only issue for decision is whether he erred in disallowing the difference of $6,533.24. The facts have been stipulated.
The petitioner, a corporation, filed its returns for 1943 with the collector of internal…
2Cited by8 opinions
- Texas Instruments, Inc. v. United StatesDistrict Court, N.D. Texas · 1976
- Volckening, Inc. v. CommissionerUnited States Tax Court · 1949
- South Penn Oil Co. v. CommissionerUnited States Tax Court · 1951
- Philadelphia Suburban Transp. Co. v. SmithDistrict Court, E.D. Pennsylvania · 1952
- Saalfield Pub. Co. v. CommissionerUnited States Tax Court · 1948
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