Legal Opinion

Sherwin-Williams Co. Employee Health Plan Trust v. Commissioner

United States Tax Court

Decided November 9, 2000No. 21333-97Published

Trust (T), a tax-exempt voluntary employees' beneficiary association described in sec. 501(c)(9), I.R.C., set aside for each year at issue a certain amount of investment income to provide for the payment of reasonable costs of administration directly connected with providing for the payment of health care benefits (amount of investment income at issue). HELD: In determining for each year at issue the unrelated business taxable income (UBTI) of T under sec. 512(a)(3)(A),…

Read the full summary

Trust (T), a tax-exempt voluntary employees' beneficiary association described in sec. 501(c)(9), I.R.C., set aside for each year at issue a certain amount of investment income to provide for the payment of reasonable costs of administration directly connected with providing for the payment of health care benefits (amount of investment income at issue). HELD: In determining for each year at issue the unrelated business taxable income (UBTI) of T under sec. 512(a)(3)(A), I.R.C., the amount of investment income at issue is subject to the limitation prescribed by sec. 512(a)(3)(E)(i), I.R.C.…

1Opinion of the Court

SHERWIN-WILLIAMS COMPANY EMPLOYEE HEALTH PLAN TRUST, KEY TRUST COMPANY OF OHIO, TRUSTEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Sherwin-Williams Co. Employee Health Plan Trust v. Commissioner

No. 21333-97

United States Tax Court

115 T.C. 440; 2000 U.S. Tax Ct. LEXIS 81; 115 T.C. No. 33;

November 9, 2000, Filed

Decision will be entered for respondent.

Trust (T), a tax-exempt voluntary employees' beneficiary

association described in sec. 501(c)(9), I.R.C., set aside for

each year at issue a certain amount of investment income to

provide for the payment of reasonable costs of…

2Cases cited8 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
  3. Fernandez v. CommissionerUnited States Tax Court · 2000
  4. Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
  5. Casa de La Jolla Park, Inc. v. CommissionerUnited States Tax Court · 1990

3 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API