Legal Opinion

Plastic Engineering & Mfg. Co. v. Commissioner

United States Tax Court

Decided June 30, 1982No. Docket No. 6724-78PublishedCited by 1 opinion

P was incorporated on Sept. 15, 1974, and elected to report its income on a fiscal year basis ending Jan. 31. On Sept. 30, 1974, P adopted a defined benefit pension plan with a plan year ending Sept. 30. Prior to Jan. 31, 1975, P made contributions to the plan equal to the normal cost of funding the 12-month plan year beginning Sept. 30, 1974. P claimed deductions for the full amount of its contributions on its return for its first, short taxable year covering from Sept. 15,…

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P was incorporated on Sept. 15, 1974, and elected to report its income on a fiscal year basis ending Jan. 31. On Sept. 30, 1974, P adopted a defined benefit pension plan with a plan year ending Sept. 30. Prior to Jan. 31, 1975, P made contributions to the plan equal to the normal cost of funding the 12-month plan year beginning Sept. 30, 1974. P claimed deductions for the full amount of its contributions on its return for its first, short taxable year covering from Sept. 15, 1974, through Jan. 31, 1975. Held, the requirement that services actually be rendered concerns only the fact of…

1Opinion of the Court

OPINION

Wilbur, Judge-.

Respondent has determined a deficiency of $6,452.27 in petitioner’s Federal income tax for its 1975 taxable year. The sole issue presented concerns whether petitioner properly deducted its contributions to a qualified pension plan.

All of the facts have been stipulated and are found accordingly. A brief summary of the salient facts follows.

Plastic Engineering & Manufacturing Co. (hereinafter referred to as petitioner or Plastic) is a Connecticut corporation having its offices located in New Britain, Conn., at the time the petition herein was filed. Petitioner filed its…

2Cases cited4 opinions

  1. United States v. CalderonSupreme Court of the United States · 1954
  2. United States v. SanchezSupreme Court of the United States · 1950
  3. Bianchi v. CommissionerUnited States Tax Court · 1976
  4. La Mastro v. CommissionerUnited States Tax Court · 1979

3Cited by1 opinion

  1. Plastic Engineering & Mfg. Co. v. CommissionerUnited States Tax Court · 1982

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