Sherwin-Williams Co. Employee Health Plan Trust v. Commissioner
United States Tax Court
Trust (T), a tax-exempt voluntary employees' beneficiary association described in sec. 501(c)(9), I.R.C., set aside for each year at issue a certain amount of investment income to provide for the payment of reasonable costs of administration directly connected with providing for the payment of health care benefits (amount of investment income at issue). HELD: In determining for each year at issue the unrelated business taxable income (UBTI) of T under sec. 512(a)(3)(A),…
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Trust (T), a tax-exempt voluntary employees' beneficiary association described in sec. 501(c)(9), I.R.C., set aside for each year at issue a certain amount of investment income to provide for the payment of reasonable costs of administration directly connected with providing for the payment of health care benefits (amount of investment income at issue). HELD: In determining for each year at issue the unrelated business taxable income (UBTI) of T under sec. 512(a)(3)(A), I.R.C., the amount of investment income at issue is subject to the limitation prescribed by sec. 512(a)(3)(E)(i), I.R.C.…
1Opinion of the Court
OPINION1
Chiechi, Judge:
Respondent determined the following deficiencies in the Federal income tax (tax) of The Sherwin-Wil-liams Co. Employee Health Plan Trust (trust):
Year Deficiency
$489,941 rH 05 05 I — I
339,924 <N 05 05 T — I
The issues for decision are:(1) In determining for each year at issue the unrelated business taxable income (UBTl) of the trust under section 512(a)(3)(A),2 is the amount of investment income that the trust set aside3 to provide for the payment of reasonable costs of administration directly connected with providing for the payment of health care benefits subject to the…
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
- Fernandez v. CommissionerUnited States Tax Court · 2000
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
- Casa de La Jolla Park, Inc. v. CommissionerUnited States Tax Court · 1990
2 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Sherwin Williams Co. Employee Health Plan Trust v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2003
- Sherwin-Williams Co. Employee Health Plan Trust v. CommissionerUnited States Tax Court · 2000
- Sherwin-Williams Company Employee Health Plan Trust v. CommissionerUnited States Tax Court · 2000