Legal Opinion
Wachtell, Lipton, Rosen & Katz, David M. Einhorn, Tax Matters Partner v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 6, 1994No. 610, Docket 93-4108PublishedCited by 23 opinions
1Opinion of the Court
PIERCE, Circuit Judge:
The Commissioner of Internal Revenue (the “Commissioner”) appeals from a decision of the United States Tax Court (Clapp, Judge), which redetermined the allowability of a portion of certain tax deductions taken by the partners of petitioner-appellee Wach-tell, Lipton, Rosen & Katz for pension plan contributions made in 1986. In a memorandum opinion filed July 14, 1992, the Tax Court held that the actuarial assumptions used to calculate the subject contributions were reasonable in the aggregate under Internal Revenue Code (“I.R.C.” or “Tax Code”) § 412(c)(3) and…
2Cases cited7 opinions
- Tennessee Valley Authority v. HillSupreme Court of the United States · 1978
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Bausch & Lomb Incorporated and Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Vinson & Elkins, J. Evans Attwell, Tax Matters Partner v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1993
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3Cited by23 opinions
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- United Mine Workers of America v. Energy West Mining CompanyCourt of Appeals for the D.C. Circuit · 2022
- Shepley v. New Coleman Holdings Inc.Court of Appeals for the Second Circuit · 1999
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