American Stores Co. v. Commissioner
United States Tax Court
P made contractually required monthly contributions to 39 multiemployer pension plans. P also provided vacation pay benefits to its employees under various plans.
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P made contractually required monthly contributions to 39 multiemployer pension plans. P also provided vacation pay benefits to its employees under various plans. For its TYE Jan. 31, 1987 (8701), P obtained an extension of the time within which to file its U.S. consolidated corporate income tax return to Oct. 15, 1987. For its TYE Jan. 30, 1988 (8801), P obtained an extension of the time within which to file its U.S. consolidated corporate income tax return to Oct. 17, 1988. On its return for TYE 8801 P deducted, in addition to the 12 monthly contributions based on units of service worked…
1Opinion of the Court
OPINION
NlMS, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income tax:
TYE
Deficiency
Feb. 2, 1985 . $3,704,320
Feb. 1, 1986 . 726,452
Jan. 31, 1987 . 43,266,274
Jan. 30, 1988 . 29,480,791
Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions, the following two issues remain for us to resolve in the present proceeding: (1) Whether petitioner, in its taxable year ending January 30, 1988 (tye 8801),…
2Cases cited9 opinions
- Reisman v. CaplinSupreme Court of the United States · 1964
- United States v. FlannerySupreme Court of the United States · 1925
- Commissioner v. KorellSupreme Court of the United States · 1950
- Oberman Mfg. Co. v. CommissionerUnited States Tax Court · 1967
- E. H. Sheldon & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Vons Companies, Inc. v. United StatesUnited States Court of Federal Claims · 2001
- American Stores Co. v. CommissionerCourt of Appeals for the Tenth Circuit · 1999
- Vons Companies, Inc. v. United StatesUnited States Court of Federal Claims · 2003
- American Stores Co. v. CommissionerUnited States Tax Court · 1997
- American Stores Company and Subsidiaries v. CommissionerUnited States Tax Court · 1997