South Penn Oil Co. v. Commissioner
United States Tax Court
1. A trust, forming part of a pension plan, was created by petitioner in 1933, within the meaning of section 165 (a), I. R. C., and the amendments made thereto by the Revenue Act of 1942. 2. The amount of deductions to which petitioner is entitled on account of its contributions to such trust pursuant to section 23 (p), I. R. C., as amended by the Revenue Act of 1942, determined for 1942, 1943, and 1944. 3. The amount of deductions to which petitioner is annually entitled…
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1. A trust, forming part of a pension plan, was created by petitioner in 1933, within the meaning of section 165 (a), I. R. C., and the amendments made thereto by the Revenue Act of 1942. 2. The amount of deductions to which petitioner is entitled on account of its contributions to such trust pursuant to section 23 (p), I. R. C., as amended by the Revenue Act of 1942, determined for 1942, 1943, and 1944. 3. The amount of deductions to which petitioner is annually entitled for the years 1943 and 1944 as "normal cost" of the plan for those respective years under section 23 (p) (1) (A) (iii) is…
1Opinion of the Court
OPINION.
Leech, Judge:
The first issue is whether petitioner is entitled to deductions for the taxable years 1942, 1943, and 1944 in the amounts of $299,572.44, $262,074.29, and $102,798.72, respectively, on account of payments to or deposits with Equitable in the years 1933 to 1937, inclusive, with respect to services of petitioner’s employees rendered prior to 1933.
The amounts of these contested deductions are not in dispute. Nor is the right thereto contested if the payments of the amounts basing these deductions were made to a trust which was within the meaning of “trust” as used in section…
2Cases cited13 opinions
- Kane v. BloodgoodNew York Court of Chancery · 1823
- Tavannes Watch Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1949
- 555, Inc. v. CommissionerUnited States Tax Court · 1950
- Pittsburgh National Bank of Commerce v. McMurraySupreme Court of Pennsylvania · 1881
- Worcester Bank & Trust Co. v. NordblomMassachusetts Supreme Judicial Court · 1933
8 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Texas Instruments Incorporated, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Community Services, Incorporated v. The United StatesUnited States Court of Claims · 1970
- Community Services, Incorporated v. The United StatesUnited States Court of Claims · 1970
- South Penn Oil Co. v. CommissionerUnited States Tax Court · 1951