Legal Opinion
Harry A. Wellons, Jr., M.D., S.C. v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided August 4, 1994No. 93-2991, 93-2992PublishedCited by 4 opinions
1Opinion of the Court
CUDAHY, Circuit Judge.
Cardiovascular surgeon Dr. Harry A Wel-lons, Jr. set up a severance pay plan for his employees in 1983. Dr. Wellons contributed $194,000 to the trust for the plan in 1984 and again in 1985, and deducted these amounts from his income taxes as a business expense under 29 U.S.C. § 162. The IRS disallowed the deductions on the grounds that the payments were made to a deferred compensation plan within the meaning of 26 U.S.C. § 404(a) and were not deductible. The Tax Court agreed. We affirm.
I
On July 1, 1984, Dr. Wellons adopted the Harry A. Wellons, Jr., M.D., S.C. Employee…
2Cases cited6 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Melvin Nickerson and Naomi W. Nickerson v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1983
- Latrobe Steel Co. v. CommissionerUnited States Tax Court · 1974
- Grant-Jacoby, Inc. v. CommissionerUnited States Tax Court · 1980
- New York Post Corp. v. CommissionerUnited States Tax Court · 1963
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Booth v. CommissionerUnited States Tax Court · 1997
- Wellpoint, Inc. v. CommissionerCourt of Appeals for the Seventh Circuit · 2010
- Booth v. CommissionerUnited States Tax Court · 1997
- Machacek v. Comm'rUnited States Tax Court · 2016