Inland Steel Co.

*648This corporate income tax case is before the court on the plaintiffs motion for partial summary judgment and the defendant’s cross-motion for partial summary judgment. Oral argument has been had.

Inland Steel is an accrual basis taxpayer, which seeks to deduct liabilities accrued in the taxable calendar years 1964 and 1965, and incurred under a Supplemental Unemployment Benefit (SUB) Plan set up pursuant to a collective bargaining agreement with the United Steelworkers of America, dated April 6, 1962. The deductibility of accruals under the SUB Plan for calendar years 1962 and 1963 was before…