Vons Companies, Inc. v. United States

*710OPINION

ALLEGRA, Judge.

This tax suit is before the court on the parties’ cross-motions for summary judgment. The Vons Companies, Inc. (Vons or plaintiff) seeks a refund of federal income tax arising out of the disallowance by the Internal Revenue Service (IRS) of deductions claimed for contributions made to multiemployer defined benefit pension plans. At issue is whether plaintiffs contributions to qualified retirement plans made after the close of its 1991 and 1992 taxable years, but before the extended due date for filing its returns for those years, were deductible in the year claimed under…