Legal Opinion

Wesley Heat Treating Co. v. Commissioner

United States Tax Court

Decided April 14, 1958No. Docket Nos. 58828, 58829, 58830Published

1. A contribution irrevocably paid in 1941 by taxpayer to a profit-sharing trust for employees, which contribution was distributed in 1942 and 1943, held deductible as a business expense under section 23 (a), I. R. C. 1939, where contribution together with regular wages and salaries paid constituted reasonable compensation for services rendered in 1941. 2. Contributions irrevocably made during the years 1942 through 1946 by taxpayer to profit-sharing trusts for employees,…

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1. A contribution irrevocably paid in 1941 by taxpayer to a profit-sharing trust for employees, which contribution was distributed in 1942 and 1943, held deductible as a business expense under section 23 (a), I. R. C. 1939, where contribution together with regular wages and salaries paid constituted reasonable compensation for services rendered in 1941. 2. Contributions irrevocably made during the years 1942 through 1946 by taxpayer to profit-sharing trusts for employees, which contributions were distributed to employees subsequent to years in which trusts established, held not deductible…

1Opinion of the Court

Wesley Heat Treating Co., Petitioner, v. Commissioner of Internal Revenue, Respondent. Spindler Metal Processing Co., Petitioner, v. Commissioner of Internal Revenue, Respondent. Wesley Steel Treating Co., Petitioner, v. Commissioner of Internal Revenue, Respondent

Wesley Heat Treating Co. v. Commissioner

Docket Nos. 58828, 58829, 58830

United States Tax Court

30 T.C. 10; 1958 U.S. Tax Ct. LEXIS 216;

April 14, 1958, Filed

Decisions will be entered under Rule 50.

1. A contribution irrevocably paid in 1941 by taxpayer to a profit-sharing trust for employees, which contribution was distributed in 1942…

2Cases cited14 opinions

  1. American Properties, Inc. v. CommissionerUnited States Tax Court · 1957
  2. Tavannes Watch Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1949
  3. Lord v. CommissionerUnited States Tax Court · 1942
  4. Pullman, Inc. v. CommissionerUnited States Tax Court · 1947
  5. Wesley Heat Treating Co. v. CommissionerUnited States Tax Court · 1958

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