American Stores Co. v. Commissioner

ANDERSON, Circuit Judge.

American Stores Company and Subsidiaries (American) appeals the decision of the United States Tax Court sustaining the Commissioner’s disallowance of deductions on its 1988 tax return for more than 12 months’ contributions to qualified multiemployer defined-benefit pension plans, and deductions on its 1987 and 1988 tax returns for certain amounts attributed to vacation pay. It also alleges that the Tax Court erred when it denied American’s motions for reconsideration, judicial notice of various administrative materials, and a hearing on those motions. We affirm.

I.…