Legal Opinion

Saalfield Pub. Co. v. Commissioner

United States Tax Court

Decided November 1, 1948No. Docket No. 15535Published

Deductions -- Pension Trust -- Section 23 (p) (1) (A), I. R. C. -- Held that, under 23 (p) (1) (A) (i) and (ii), the taxpayer is entitled to deduct in full the amount paid to an employees' pension trust which is actuarially necessary to provide with respect to all employees under the trust the remaining unfunded cost of their past and current service credits distributed as a level amount over the remaining future service of each such employee, even though such amount exceeds…

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Deductions -- Pension Trust -- Section 23 (p) (1) (A), I. R. C. -- Held that, under 23 (p) (1) (A) (i) and (ii), the taxpayer is entitled to deduct in full the amount paid to an employees' pension trust which is actuarially necessary to provide with respect to all employees under the trust the remaining unfunded cost of their past and current service credits distributed as a level amount over the remaining future service of each such employee, even though such amount exceeds the deduction allowable under 23 (p) (1) (A) (iii); held, further, section 29.23 (p)-6 of Regulations 111 so applied as…

1Opinion of the Court

The Saalfield Publishing Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Saalfield Pub. Co. v. Commissioner

Docket No. 15535

United States Tax Court

11 T.C. 756; 1948 U.S. Tax Ct. LEXIS 42;

November 1, 1948, Promulgated

Decision will be entered under Rule 50.

Deductions -- Pension Trust -- Section 23 (p) (1) (A), I. R. C. -- Held that, under 23 (p) (1) (A) (i) and (ii), the taxpayer is entitled to deduct in full the amount paid to an employees' pension trust which is actuarially necessary to provide with respect to all employees under the trust the remaining unfunded cost of…

2Cases cited1 opinion

  1. Saalfield Pub. Co. v. CommissionerUnited States Tax Court · 1948

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