Precision Industries, Inc. v. Commissioner
United States Tax Court
Petitioner, an accrual basis taxpayer with a fiscal year ending Mar. 31, adopted a Master Profit-Sharing Plan on or about Mar. 10, 1970, and contributed $ 100 to the trust at the time. Under the plan petitioner's board of directors was to determine before the end of each year the amount it would contribute to the plan and accrue its liability therefrom on its books and records. The plan did not prescribe a contribution formula.
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Petitioner, an accrual basis taxpayer with a fiscal year ending Mar. 31, adopted a Master Profit-Sharing Plan on or about Mar. 10, 1970, and contributed $ 100 to the trust at the time. Under the plan petitioner's board of directors was to determine before the end of each year the amount it would contribute to the plan and accrue its liability therefrom on its books and records. The plan did not prescribe a contribution formula. Petitioner's directors did not formally determine or record on its books before Mar. 31, 1970, the amount it would contribute to the plan for fiscal 1970 but before…
1Opinion of the Court
Drennen, Judge:
Respondent determined a deficiency in petitioner’s income tax for the taxable year ended March 31, 1970, in the amount of $8,457.73.
The sole issue for determination is whether petitioner, an accrual basis taxpayer, had incurred a fixed liability in the fiscal year ended March 31, 1970, to contribute the sum of $16,200 to a qualified profit-sharing plan. If petitioner was obligated to make this payment as of the end of the fiscal year, then it could properly deduct the contribution in that year under section 404, I.R.C. 1954.
FINDINGS OF FACT
Some of the facts have been stipulated…
2Cases cited4 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Aero Rental v. CommissionerUnited States Tax Court · 1975
- West Virginia Steel Corp. v. CommissionerUnited States Tax Court · 1960
- Chesapeake Corp. of Virginia v. CommissionerUnited States Tax Court · 1951
3Cited by9 opinions
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- Raybestos Manhattan, Inc. v. United StatesUnited States Court of Claims · 1979
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