Legal Opinion

Produce Reporter Co. v. Commissioner

United States Tax Court

Decided April 10, 1952No. Docket No. 24044Published

1. The two trusts created by petitioner for the sole benefit of its employees with five or more years of service, pursuant to a plan for sharing its profits, meet all the requirements to qualify them as exempt under section 165 (a), and the contributions thereto in the respective taxable years involved are deductible as provided in section 23 (p), Internal Revenue Code. 2. Petitioner, on the accrual system of accounting, properly accrued bonus payments to its employees in…

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1. The two trusts created by petitioner for the sole benefit of its employees with five or more years of service, pursuant to a plan for sharing its profits, meet all the requirements to qualify them as exempt under section 165 (a), and the contributions thereto in the respective taxable years involved are deductible as provided in section 23 (p), Internal Revenue Code. 2. Petitioner, on the accrual system of accounting, properly accrued bonus payments to its employees in the respective year when authorized by its directors and each employee advised of the exact amount he was to receive,…

1Opinion of the Court

Produce Reporter Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Produce Reporter Co. v. Commissioner

Docket No. 24044

United States Tax Court

18 T.C. 69; 1952 U.S. Tax Ct. LEXIS 222;

April 10, 1952, Promulgated

Decision will be entered under Rule 50.

1. The two trusts created by petitioner for the sole benefit of its employees with five or more years of service, pursuant to a plan for sharing its profits, meet all the requirements to qualify them as exempt under section 165 (a), and the contributions thereto in the respective taxable years involved are deductible as provided in…

2Cases cited4 opinions

  1. Wooster Rubber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951
  2. Lincoln Electric Co. Employees' Profit-Sharing Trust v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951
  3. Lincoln Electric Co. Employees' Profit-Sharing Trust v. CommissionerUnited States Tax Court · 1950
  4. Produce Reporter Co. v. CommissionerUnited States Tax Court · 1952

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