Crow-Burlingame Co. v. Commissioner
United States Tax Court
1. On December 11, 1943, petitioner's directors passed a resolution approving the establishment of an employees' pension plan and trust and appropriated irrevocably $ 30,000 thereto. On December 15, 1943, a tentative trust agreement was executed. The plan and trust were to meet with the approval of the governmental units having jurisdiction over them. Petitioner's employees were notified of this action.
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1. On December 11, 1943, petitioner's directors passed a resolution approving the establishment of an employees' pension plan and trust and appropriated irrevocably $ 30,000 thereto. On December 15, 1943, a tentative trust agreement was executed. The plan and trust were to meet with the approval of the governmental units having jurisdiction over them. Petitioner's employees were notified of this action. On February 29, 1944, petitioner deposited its check for $ 30,000 as its first payment to the trust in accordance with the resolution and agreement. On December 11, 1944, petitioner's…
1Opinion of the Court
OPINION.
Black, Judge:
Employees’ pension plan. — Under this issue the question is whether respondent erred in determining that petitioner was not entitled to deduct its contributions to a claimed employees’ pension trust for the years 1943 and 1944. Respondent contends that petitioner did not have in effect during the taxable years ended December 31, 1943, and December 31, 1944, an employees’ pension plan and trust within the meaning of those terms as used in sections 23 (p) and 165 (a) of the Internal Revenue Code. Petitioner contends that its contributions are deductible under sections 23…
2Cases cited8 opinions
- William Leveen Corp. v. CommissionerUnited States Tax Court · 1944
- Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
- McKee v. ParadiseSupreme Court of the United States · 1936
- Surface Combustion Corp. v. CommissionerUnited States Tax Court · 1947
- Denman Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1950
3 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Engineered Timber Sales, Inc. v. CommissionerUnited States Tax Court · 1980
- Crow-Burlingame Co. v. CommissionerUnited States Tax Court · 1950
- Engineered Timber Sales, Inc. v. CommissionerUnited States Tax Court · 1980