Ford Motor Co. v. Commissioner
United States Tax Court
P settled various tort claims by entering into "structured settlements" with the tort claimants. P was obligated under the terms of the settlement agreements to make a series of payments to each of the tort claimants over various periods, the longest of which was 58 years. P purchased single premium annuity contracts to fund the series of payments P was obligated to make to the tort claimants.
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P settled various tort claims by entering into "structured settlements" with the tort claimants. P was obligated under the terms of the settlement agreements to make a series of payments to each of the tort claimants over various periods, the longest of which was 58 years. P purchased single premium annuity contracts to fund the series of payments P was obligated to make to the tort claimants. The present value of P's obligations to the tort claimants does not exceed the amount P paid for the annuity contracts. P, an accrual basis taxpayer, claims a deduction for its 1980 taxable year for the…
1Opinion of the Court
Ford Motor Company and Affiliated Companies, Petitioners v. Commissioner of Internal Revenue, Respondent
Ford Motor Co. v. Commissioner
Docket No. 14949-91
United States Tax Court
102 T.C. 87; 1994 U.S. Tax Ct. LEXIS 6; 102 T.C. No. 6;
January 31, 1994, Filed
Decision will be entered under Rule 155.
P settled various tort claims by entering into "structured settlements" with the tort claimants. P was obligated under the terms of the settlement agreements to make a series of payments to each of the tort claimants over various periods, the longest of which was 58 years. P purchased single premium…
Also in this document: Dissent.
2Cases cited46 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Patrick J. O'COnnOr v. Robert W. SteevesCourt of Appeals for the First Circuit · 1993
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- United States v. Southwestern Cable Co.Supreme Court of the United States · 1968
- Rainwater v. United StatesSupreme Court of the United States · 1958
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