Albertson's, Inc. v. Commissioner
United States Tax Court
P, an accrual basis taxpayer, established nonqualified deferred compensation arrangements (DCA's) for eight "key" executives and one outside member of its board of directors (DCA participants). Under the DCA's, P and the DCA participants agreed to defer payments for future personal services the DCA participants would otherwise have been entitled to receive upon the performance of those services.
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P, an accrual basis taxpayer, established nonqualified deferred compensation arrangements (DCA's) for eight "key" executives and one outside member of its board of directors (DCA participants). Under the DCA's, P and the DCA participants agreed to defer payments for future personal services the DCA participants would otherwise have been entitled to receive upon the performance of those services. The DCA's were unfunded and represented the unsecured contractual obligations of P to pay each DCA participant upon termination, retirement, or attainment of a specified age. P maintained bookkeeping…
1Opinion of the Court
RUWE, Judge:*
Respondent determined a deficiency in petitioner’s Federal income tax in the amount of $718,936 for fiscal year ending February 3, 1983. Originally, three issues were presented for decision: (1) The investment tax credit issue; (2) the WIN credit issue; and (3) the interest/deferred compensation issue. By an order dated December 27, 1988, this Court severed the investment tax credit issue from the other issues and decided it in petitioner’s favor. See Albertson’s, Inc. v. Commissioner, T.C. Memo. 1988-582. Supplemental briefs with respect to the WIN credit and the…
2Cases cited23 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
18 more not listed; retrieve them via the Exa API.
3Cited by43 opinions
- Kovacs v. CommissionerUnited States Tax Court · 1993
- Albertson's, Inc., Petitioner-Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-AppellantCourt of Appeals for the Ninth Circuit · 1994
- Booth v. CommissionerUnited States Tax Court · 1997
- Bank One Corp. v. Comm'rUnited States Tax Court · 2003
- Midkiff v. CommissionerUnited States Tax Court · 1991
38 more not listed; retrieve them via the Exa API.