Legal Opinion
Schmidt Baking Company, Inc. v. Commissioner
United States Tax Court
Decided November 14, 1996No. 10458-95Unknown
1Opinion of the Court
107 T.C. No. 16
UNITED STATES TAX COURT SCHMIDT BAKING COMPANY, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10458-95. Filed November 14, 1996. P funded its vacation and severance pay obligations to its employees for 1991 by purchasing an irrevocable letter of credit on March 13, 1992. The letter of credit constituted a transfer of an interest in substantially vested property, includable in income of the employees as of that date under sec. 83, I.R.C. P, an accrual basis taxpayer, deducted the amount of the letter of credit on its 1991 return on the basis that it…
2Cases cited11 opinions
- Zinniel v. CommissionerUnited States Tax Court · 1987
- Truck & Equipment Corp. v. CommissionerUnited States Tax Court · 1992
- Albertson's, Inc. v. CommissionerUnited States Tax Court · 1990
- Albertson's, Inc., Petitioner-Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-AppellantCourt of Appeals for the Ninth Circuit · 1994
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1996
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