Legal Opinion

Reynolds Metals Co. v. Commissioner

United States Tax Court

Decided September 26, 1977No. Docket No. 9705-75Published

Petitioner, an accrual basis taxpayer, contracted to make certain payments to three separate funds administered by three separate trusts to provide supplemental unemployment benefit payments to its employees represented by the United Steelworkers of America, the Aluminum Workers International Union, and the craft unions, except for the brickmasons, at its McCook plant. The amounts of all the payments to be made were determined by events occurring during the years in issue.

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Petitioner, an accrual basis taxpayer, contracted to make certain payments to three separate funds administered by three separate trusts to provide supplemental unemployment benefit payments to its employees represented by the United Steelworkers of America, the Aluminum Workers International Union, and the craft unions, except for the brickmasons, at its McCook plant. The amounts of all the payments to be made were determined by events occurring during the years in issue. However only a part of this liability for each fund was required to be made immediately in cash, the balance to be funded…

1Opinion of the Court

Reynolds Metals Company Common Parent Corporation of Reynolds Metals Company and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent

Reynolds Metals Co. v. Commissioner

Docket No. 9705-75

United States Tax Court

68 T.C. 943; 1977 U.S. Tax Ct. LEXIS 44;

September 26, 1977, Filed

Decision will be entered for the petitioner.

Petitioner, an accrual basis taxpayer, contracted to make certain payments to three separate funds administered by three separate trusts to provide supplemental unemployment benefit payments to its employees represented by the United Steelworkers of America,…

2Cases cited7 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Lucas v. American Code Co.Supreme Court of the United States · 1930
  3. Lukens Steel Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1971
  4. Reynolds Metals Co. v. CommissionerUnited States Tax Court · 1977
  5. Commissioner of Internal Revenue v. Brooklyn Radio Service Corp.Court of Appeals for the Second Circuit · 1935

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