Jacobs v. Commissioner
United States Tax Court
In April 1959, Credit, Inc., an accrual basis taxpayer, agreed to pay a retiring employee $ 100 per month until such payments totaled $ 10,000 or until she died, whichever occurred first. The corporation made 10 such payments between the signing of the agreement and February 1960, the date of its liquidation. Pursuant to the liquidation, its shareholders assumed the corporation's obligation under the agreement.
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In April 1959, Credit, Inc., an accrual basis taxpayer, agreed to pay a retiring employee $ 100 per month until such payments totaled $ 10,000 or until she died, whichever occurred first. The corporation made 10 such payments between the signing of the agreement and February 1960, the date of its liquidation. Pursuant to the liquidation, its shareholders assumed the corporation's obligation under the agreement. In its final return, Credit, Inc., claimed a "pension deduction" for the actuarially computed value of the unpaid obligation. Respondent disallowed the deduction. Held, the obligation…
1Opinion of the Court
Sol Jacobs, Jr., Transferee, Petitioner, v. Commissioner of Internal Revenue, Respondent
Jacobs v. Commissioner
Docket No. 3475-63
United States Tax Court
45 T.C. 133; 1965 U.S. Tax Ct. LEXIS 20;
October 28, 1965, Filed
Decision will be entered for the respondent.
In April 1959, Credit, Inc., an accrual basis taxpayer, agreed to pay a retiring employee $ 100 per month until such payments totaled $ 10,000 or until she died, whichever occurred first. The corporation made 10 such payments between the signing of the agreement and February 1960, the date of its liquidation. Pursuant to the liquidation,…
2Cases cited26 opinions
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Commissioner of Internal Revenue v. CarterCourt of Appeals for the Second Circuit · 1948
- Jud Plumbing & Heating, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Central Cuba Sugar Co. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Central Cuba Sugar CoCourt of Appeals for the Second Circuit · 1952
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