Champion Spark Plug Co. v. Commissioner
United States Tax Court
Petitioner's board of directors, on December 16, 1953, adopted a resolution providing for the payment of $ 33,750 to an employee disabled because of illness, the payments to be made in 60 semimonthly installments over 30 months beginning with January 15, 1954, and to be made to the employee, or his widow, or her estate.
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Petitioner's board of directors, on December 16, 1953, adopted a resolution providing for the payment of $ 33,750 to an employee disabled because of illness, the payments to be made in 60 semimonthly installments over 30 months beginning with January 15, 1954, and to be made to the employee, or his widow, or her estate. Held, petitioner, on the accrual basis of accounting, properly accrued the authorized payment of $ 33,750 in 1953 and was entitled to the deduction in that year as an accruable item of ordinary and necessary business expense. Held, further, section 23 (p), I. R. C. 1939, did…
1Opinion of the Court
Mulroney, Judge:
The respondent determined a deficiency in income tax of the petitioner for the year 1953 in the sum of $27,670.94. The only issue in the case is whether petitioner properly accrued and deducted for the year 1953 the amount of $33,750 representing a sum provided and authorized by the petitioner’s board of directors on December 16, 1953, for payment in 60 equal semimonthly installments commencing January 15, 1954, the payments to be made to a disabled employee or his widow or her estate.
FINDINGS OF FACT.
Some of the facts have been stipulated and they are found accordingly.
The…
2Cited by35 opinions
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- Commissioner of Internal Revenue v. H. B. Ives CompanyCourt of Appeals for the Second Circuit · 1961
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