I. S. C., Inc. v. Commissioner
United States Tax Court
(1) P is an accrual method taxpayer with a taxable year ending Sept. 30. On Sept. 21, 1970, the board of directors of P approved a proposed stock bonus plan, authorized execution of the plan and creation of a trust, and authorized a contribution to the trust.
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(1) P is an accrual method taxpayer with a taxable year ending Sept. 30. On Sept. 21, 1970, the board of directors of P approved a proposed stock bonus plan, authorized execution of the plan and creation of a trust, and authorized a contribution to the trust. A written plan was executed the same day, but the trust agreement was not executed, and the contribution was not made, until June 14, 1971, one day prior to the last day for the filing of its return for the year ending Sept. 30, 1970. Held, a stock bonus trust qualified under sec. 401(a), I.R.C. 1954, did not exist in P's taxable year…
1Opinion of the Court
I.S.C., INCORPORATED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
I. S. C., Inc. v. Commissioner
Docket No. 3653-74.
United States Tax Court
T.C. Memo 1978-288; 1978 Tax Ct. Memo LEXIS 223; 37 T.C.M. (CCH) 1206; T.C.M. (RIA) 78288;
July 27, 1978, Filed(1) P is an accrual method taxpayer with a taxable year ending Sept. 30. On Sept. 21, 1970, the board of directors of P approved a proposed stock bonus plan, authorized execution of the plan and creation of a trust, and authorized a contribution to the trust. A written plan was executed the same day, but the trust agreement was not…
2Cases cited31 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
26 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Attardo v. CommissionerUnited States Tax Court · 1991