Albertson's, Inc. v. Commissioner
United States Tax Court
P, an accrual basis taxpayer, established nonqualified deferred compensation arrangements (DCA's) for eight "key" executives and one outside member of its board of directors (DCA participants). Under the DCA's, P and the DCA participants agreed to defer payments for future personal services the DCA participants would otherwise have been entitled to receive upon the performance of those services.
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P, an accrual basis taxpayer, established nonqualified deferred compensation arrangements (DCA's) for eight "key" executives and one outside member of its board of directors (DCA participants). Under the DCA's, P and the DCA participants agreed to defer payments for future personal services the DCA participants would otherwise have been entitled to receive upon the performance of those services. The DCA's were unfunded and represented the unsecured contractual obligations of P to pay each DCA participant upon termination, retirement, or attainment of a specified age. P maintained bookkeeping…
1Opinion of the Court
Albertson's, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Albertson's, Inc. v. Commissioner
Docket No. 10439-87
United States Tax Court
95 T.C. 415; 1990 U.S. Tax Ct. LEXIS 99; 95 T.C. No. 30; 12 Employee Benefits Cas. (BNA) 2567;
October 9, 1990, Filed
Decision will be entered under Rule 155.
P, an accrual basis taxpayer, established nonqualified deferred compensation arrangements (DCA's) for eight "key" executives and one outside member of its board of directors (DCA participants). Under the DCA's, P and the DCA participants agreed to defer payments for future personal services…
Also in this document: Concurrence; Dissent.
2Cases cited25 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
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