Crucible Inc. v. United States

The principal issue in this case, here on cross-motions for summary judgment, is whether in its federal income tax returns the plaintiff properly deducted in the year of accrual amounts accrued under its 1962 *126Supplemental Unemployment Benefits ("SUB”) Plan. For the reasons explained below, we grant in part and deny in part each motion for summary judgment, and remand the case to the Trial Division for proceedings in accordance with this opinion.

I

Crucible Steel Company ("Crucible Steel”), an accrual-basis taxpayer to which the plaintiff is the successor in interest,1 was a steel manufacturer.…