Frank Shepard Co. v. Commissioner
United States Tax Court
Since its incorporation in 1900 petitioner has been continuously engaged in the business of compiling and publishing legal citations. Early in 1938, due to the sense of social responsibility to do something towards providing for the superannuation of its older employees, it pensioned 2 of its employees, who were no longer able to work. Later in 1938 it purchased annuity policies, to commence at age 65, for a number of other employees.
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Since its incorporation in 1900 petitioner has been continuously engaged in the business of compiling and publishing legal citations. Early in 1938, due to the sense of social responsibility to do something towards providing for the superannuation of its older employees, it pensioned 2 of its employees, who were no longer able to work. Later in 1938 it purchased annuity policies, to commence at age 65, for a number of other employees. In 1939 it continued to pay pensions to the 2 employees pensioned in the previous year, and purchased additional annuity policies for others. The amounts so…
1Opinion of the Court
OPINION.
Black, Judge:
We shall consider together the four issues set out in our preliminary statement. They are so closely connected that they can be treated together. The applicable statute1 and regulations 2 are set forth in the margin.
Our first problem is to determine to what extent the deductions in 1938 and 1939 for premiums and pensions come within the term “class” as that term is used in the applicable statute. The determination of that issue is considerably clarified by our recent holding on issue No. 5 in Arrow-Hart & Hegeman Electric Co., 7 T. C. 1350, 1372. There we held that…
2Cases cited5 opinions
- Truax v. CorriganSupreme Court of the United States · 1921
- Green Bay Lumber Co. v. CommissionerUnited States Tax Court · 1944
- Arrow-Hart & Hegeman Electric Co. v. CommissionerUnited States Tax Court · 1946
- R. C. Harvey Co. v. CommissionerUnited States Tax Court · 1945
- City Auto Stamping Co. v. CommissionerUnited States Tax Court · 1946
3Cited by15 opinions
- Universal Optical Co. v. CommissionerUnited States Tax Court · 1948
- Telfair Stockton & Co. v. CommissionerUnited States Tax Court · 1953
- Colonial Amusement Co. v. CommissionerUnited States Tax Court · 1948
- Walter Motor Truck Co. v. CommissionerUnited States Tax Court · 1951
- Frank H. Fleer Corp. v. CommissionerUnited States Tax Court · 1948
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