General Signal Corp. v. Commissioner
United States Tax Court
In December 1985, P established a voluntary employees' beneficiary association (VEBA) trust which qualified for exemption under sec. 501(c)(9), I.R.C. During the years in issue, P contributed amounts to the VEBA trust to provide medical and certain other benefits to its employees. Such amounts were primarily used to satisfy benefits claims in the year following the year of contribution.
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In December 1985, P established a voluntary employees' beneficiary association (VEBA) trust which qualified for exemption under sec. 501(c)(9), I.R.C. During the years in issue, P contributed amounts to the VEBA trust to provide medical and certain other benefits to its employees. Such amounts were primarily used to satisfy benefits claims in the year following the year of contribution. Although the VEBA trust was authorized to provide postretirement medical and life insurance benefits, in addition to current medical benefits, no reserves were established or funded for the purpose of paying…
1Opinion of the Court
NlMS, Judge:
Respondent determined deficiencies in Federal income tax with respect to petitioner’s 1986 and 1987 taxable years in the amounts of $15,388,891 and $6,787,120, respectively.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Following concessions by the parties, the sole issue to be decided in this opinion is whether and to what extent, if any, contributions made by petitioner to a welfare benefit trust during 1986 and 1987 are deductible…
2Cases cited8 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
3 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Booth v. CommissionerUnited States Tax Court · 1997
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1996
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1996
- General Signal Corp. v. CommissionerUnited States Tax Court · 1995
28 more not listed; retrieve them via the Exa API.