Wesley Heat Treating Co. v. Commissioner
United States Tax Court
1. A contribution irrevocably paid in 1941 by taxpayer to a profit-sharing trust for employees, which contribution was distributed in 1942 and 1943, held deductible as a business expense under section 23 (a), I. R. C. 1939, where contribution together with regular wages and salaries paid constituted reasonable compensation for services rendered in 1941. 2. Contributions irrevocably made during the years 1942 through 1946 by taxpayer to profit-sharing trusts for employees,…
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1. A contribution irrevocably paid in 1941 by taxpayer to a profit-sharing trust for employees, which contribution was distributed in 1942 and 1943, held deductible as a business expense under section 23 (a), I. R. C. 1939, where contribution together with regular wages and salaries paid constituted reasonable compensation for services rendered in 1941. 2. Contributions irrevocably made during the years 1942 through 1946 by taxpayer to profit-sharing trusts for employees, which contributions were distributed to employees subsequent to years in which trusts established, held not deductible…
1Opinion of the Court
Tietjens, Judge:
The Commissioner determined deficiencies in petitioners’ income tax, excess profits tax, and declared value excess-profits tax, and made additions to the tax for negligence under section 293 (a) of the Internal Revenue Code of 1939, as follows;
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The parties have stipulated the extent to which certain items disallowed as deductions by the Commissioner are properly deductible by the petitioners. There remain two issues for decision: (1) Whether petitioners’ contributions during the years 1941 through 1946 to certain profit-sharing trusts, established for the benefit…
2Cases cited12 opinions
- American Properties, Inc. v. CommissionerUnited States Tax Court · 1957
- Tavannes Watch Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1949
- Lord v. CommissionerUnited States Tax Court · 1942
- Pullman, Inc. v. CommissionerUnited States Tax Court · 1947
- Times Publishing Co. v. CommissionerUnited States Tax Court · 1949
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3Cited by29 opinions
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- Cramer v. CommissionerUnited States Tax Court · 1993
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