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
South Penn Oil Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
South Penn Oil Co. v. Commissioner
Docket No. 21975
United States Tax Court
17 T.C. 27; 1951 U.S. Tax Ct. LEXIS 127;
July 17, 1951, Promulgated
Decision will be entered under Rule 50.
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…
2Cases cited14 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
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