Reynolds Metals Co. v. Commissioner
United States Tax Court
Petitioner, an accrual basis taxpayer, contracted to make certain payments to three separate funds administered by three separate trusts to provide supplemental unemployment benefit payments to its employees represented by the United Steelworkers of America, the Aluminum Workers International Union, and the craft unions, except for the brickmasons, at its McCook plant. The amounts of all the payments to be made were determined by events occurring during the years in issue.
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Petitioner, an accrual basis taxpayer, contracted to make certain payments to three separate funds administered by three separate trusts to provide supplemental unemployment benefit payments to its employees represented by the United Steelworkers of America, the Aluminum Workers International Union, and the craft unions, except for the brickmasons, at its McCook plant. The amounts of all the payments to be made were determined by events occurring during the years in issue. However only a part of this liability for each fund was required to be made immediately in cash, the balance to be funded…
1Opinion of the Court
OPINION
Sterrett, Judge:
Respondent determined deficiencies in petitioner’s corporate Federal income taxes for the calendar years 1962 and 1963 in the amounts of $1,213,379.04 and $34,800.89, respectively. The sole issue for decision is whether petitioner, an accrual basis taxpayer, may deduct, pursuant to section 162, I.R.C. 1954, the unpaid portion of its obligation at the end of 1962 and 1963 to make contributions to employees’ trusts established under a union-management negotiated supplemental unemployment benefit plan.
This case was submitted under Rule 122, Tax Court Rules of Practice and…
2Cases cited6 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Lukens Steel Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1971
- Commissioner of Internal Revenue v. Brooklyn Radio Service Corp.Court of Appeals for the Second Circuit · 1935
- Cyclops Corp. v. United StatesDistrict Court, W.D. Pennsylvania · 1976
1 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Illinois Power Co. v. CommissionerUnited States Tax Court · 1986
- Ohio River Collieries Co. v. CommissionerUnited States Tax Court · 1981
- Inland Steel Co. v. United StatesUnited States Court of Claims · 1982
- Citrus Orthopedic Medical Group, Inc. v. CommissionerUnited States Tax Court · 1979
- First Northwest Industries, Inc. v. CommissionerUnited States Tax Court · 1978
5 more not listed; retrieve them via the Exa API.