Colorado Nat'l Bank v. Commissioner
United States Tax Court
Deduction -- Contribution to Employees' Pension Trust in Property -- Paid. -- Transfer by employer of property having a fair market value in excess of amount claimed as contribution to an employees' pension trust was "paid into a pension trust" within the meaning of section 404 (a) (1) (C), I. R. C. 1954, notwithstanding leaseback of the property to the bank with option to repurchase at agreed price.
1Opinion of the Court
OPINION.
MuRdock, Judge:
The Commissioner determined a deficiency of $24,742.80 in income tax of the petitioner for 1954. The facts have been presented by a stipulation of facts which is adopted as the findings of fact. The petitioner filed its cash basis return for 1954 with the director of internal revenue at Denver, Colorado.
The petitioner claimed a deduction of $110,441.49 on its return as amounts contributed to a trust under a pension plan. The Commissioner, in determining the deficiency, disallowed $73,284.651 of that total. The only question for decision is whether the $78,284.65 was…
2Cases cited1 opinion
- Burns v. CommissionerUnited States Tax Court · 1954
3Cited by18 opinions
- F. & D. Rentals, Inc. v. CommissionerUnited States Tax Court · 1965
- Wasatch Chemical Company, a Utah Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
- Don E. Williams Co. v. CommissionerUnited States Tax Court · 1974
- Wasatch Chemical Co. v. CommissionerUnited States Tax Court · 1962
- Dallas C. Wood v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1992
13 more not listed; retrieve them via the Exa API.