Lozano, Inc. v. Commissioner
United States Tax Court
P's board of directors authorized a contribution to its profit-sharing trust before the close of the year in issue, although no record was made of such action. The contribution was paid within the statutory grace period provided in sec. 404(a)(6), I.R.C. 1954. Held, under the circumstances, P incurred an accruable liability during the year in issue and is entitled to deduct such contribution for such year.
1Opinion of the Court
Lozano, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Lozano, Inc. v. Commissioner
Docket No. 2371-75
United States Tax Court
68 T.C. 366; 1977 U.S. Tax Ct. LEXIS 96;
June 9, 1977, Filed
Decision will be entered for the petitioner.
P's board of directors authorized a contribution to its profit-sharing trust before the close of the year in issue, although no record was made of such action. The contribution was paid within the statutory grace period provided in sec. 404(a)(6), I.R.C. 1954. Held, under the circumstances, P incurred an accruable liability during the year in issue and…
2Cases cited19 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Aero Rental v. CommissionerUnited States Tax Court · 1975
- Columbia Iron & Metal Co. v. CommissionerUnited States Tax Court · 1973
- West Virginia Steel Corp. v. CommissionerUnited States Tax Court · 1960
- Champion Spark Plug Co. v. CommissionerUnited States Tax Court · 1958
14 more not listed; retrieve them via the Exa API.