Schmidt Baking Co. v. Commissioner
United States Tax Court
P funded its vacation and severance pay obligations to its employees for 1991 by purchasing an irrevocable letter of credit on March 13, 1992. The letter of credit constituted a transfer of an interest in substantially vested property, includable in income of the employees as of that date under sec. 83, I.R.C.
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P funded its vacation and severance pay obligations to its employees for 1991 by purchasing an irrevocable letter of credit on March 13, 1992. The letter of credit constituted a transfer of an interest in substantially vested property, includable in income of the employees as of that date under sec. 83, I.R.C. P, an accrual basis taxpayer, deducted the amount of the letter of credit on its 1991 return on the basis that it paid the vacation pay within 2-1/2 months of the close of its 1991 taxable year and was therefore entitled to the claimed deduction under sec. 83(h), I.R.C., and sec.…
1Opinion of the Court
SCHMIDT BAKING COMPANY, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Schmidt Baking Co. v. Commissioner
Docket No. 10458-95.
United States Tax Court
107 T.C. 271; 1996 U.S. Tax Ct. LEXIS 47; 107 T.C. No. 16; 20 Employee Benefits Cas. (BNA) 2121;
November 14, 1996, Filed
Decision will be entered under Rule 155.
P funded its vacation and severance pay obligations to its employees for 1991 by purchasing an irrevocable letter of credit on March 13, 1992. The letter of credit constituted a transfer of an interest in substantially vested property, includable in income of the employees…
2Cases cited11 opinions
- Zinniel v. CommissionerUnited States Tax Court · 1987
- Truck & Equipment Corp. v. CommissionerUnited States Tax Court · 1992
- Albertson's, Inc. v. CommissionerUnited States Tax Court · 1990
- Albertson's, Inc., Petitioner-Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-AppellantCourt of Appeals for the Ninth Circuit · 1994
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1996
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