Booth v. Commissioner
United States Tax Court
Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. L. 98-369, secs. 511(a), 512(a), 98 Stat. 494, 854, 862, limit an employer's deductions for contributions made to a welfare benefits fund for employees. These limitations do not apply to a welfare benefits fund that is part of a "10 or more employer plan" described in sec. 419A(f) (6), I.R.C.
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Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. L. 98-369, secs. 511(a), 512(a), 98 Stat. 494, 854, 862, limit an employer's deductions for contributions made to a welfare benefits fund for employees. These limitations do not apply to a welfare benefits fund that is part of a "10 or more employer plan" described in sec. 419A(f) (6), I.R.C. Under the Prime Plan, in which Ps participated, each participating employer made a one-time, nonrevertible contribution to a single trust, equal to the amount necessary to fund the dismissal wage and death benefits of its…
1Opinion of the Court
Laro, Judge:
The docketed cases, consolidated for purposes of trial, briefing, and opinion, consist of four groups of test cases selected by the parties to resolve their disputes concerning the “Prime Financial Benefits Trust Multiple Employer Welfare Benefit Plan and Trust”.2 (We hereinafter refer to this plan as the Prime plan and the trust as the trust.3) Each of these four groups consists of a closely held corporation and one or more of its owner/employees. In regard to each group, the Commissioner of Internal Revenue (the Commissioner or respondent) determined that the corporation could…
2Cases cited38 opinions
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- Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
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3Cited by39 opinions
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- National Security Systems, Inc. v. IolaCourt of Appeals for the Third Circuit · 2012
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- Finderne Mgmt. Co. v. BarrettNew Jersey Superior Court Appellate Division · 2008
- PSB Holdings, Inc. v. Comm'rUnited States Tax Court · 2007
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