Denver & R. G. W. R. Co. v. Commissioner
United States Tax Court
1. Prior to 1954 the petitioner's agreements with its employees provided that if an employee had rendered a specified number of days of service in one year he would be entitled during the following year to a vacation with pay, or pay in lieu thereof, but that no allowance would be due if, prior to the taking of the vacation, his employment should be terminated, except by retirement.
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1. Prior to 1954 the petitioner's agreements with its employees provided that if an employee had rendered a specified number of days of service in one year he would be entitled during the following year to a vacation with pay, or pay in lieu thereof, but that no allowance would be due if, prior to the taking of the vacation, his employment should be terminated, except by retirement. Effective with the year 1954 the petitioner's contracts with its employees were amended to provide that if an employee should die before taking his vacation the allowance would be paid to his surviving wife or…
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in income tax for the taxable years 1954 and 1955 in the respective amounts of $324,210.78 and $34,195.07.
By stipulation the petitioner has waived certain of its allegations of error and the respondent has conceded certain errors in his determinations. The issues remaining for decision are whether the respondent erred in (1) disallowing as deductions for the years 1954 and 1955 the amounts claimed by the petitioner as accruals of vacation allowances and allowing only the amounts actually paid in those years, (2) disallowing as a deduction…
2Cases cited32 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- United States v. AndersonSupreme Court of the United States · 1926
- Brown v. HelveringSupreme Court of the United States · 1934
- Bartels v. BirminghamSupreme Court of the United States · 1947
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3Cited by34 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Putoma Corp., Successor by Merger of Pro-Mac Company, Petitioners- Cross-Appellants v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1979
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- Union Pacific Railroad v. United StatesUnited States Court of Claims · 1975
- Baker v. United StatesUnited States Court of Claims · 1980
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