Legal Opinion

David R. Webb Co. v. Commissioner

United States Tax Court

Decided November 19, 1981No. Docket No. 14123-78Published

P acquired all the assets and liabilities of X, including the express assumption of the liability to pay an unfunded pension to G, the widow of a former employee. P made and deducted its payments to G. Held: P's payment of X's obligation to G was not an ordinary and necessary business expense. Rather, such payments, in the year paid, became part of P's cost basis in the assets it purchased from X.

1Opinion of the Court

David R. Webb Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

David R. Webb Co. v. Commissioner

Docket No. 14123-78

United States Tax Court

77 T.C. 1134; 1981 U.S. Tax Ct. LEXIS 24;

November 19, 1981, Filed

Decision will be entered for the respondent.

P acquired all the assets and liabilities of X, including the express assumption of the liability to pay an unfunded pension to G, the widow of a former employee. P made and deducted its payments to G. Held: P's payment of X's obligation to G was not an ordinary and necessary business expense. Rather, such payments, in the…

2Cases cited13 opinions

  1. United States v. Philip K. Smith, United States of America v. McIver & Smith Fabricators, Inc.Court of Appeals for the Fifth Circuit · 1969
  2. WD Haden Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
  3. F. & D. Rentals, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1966
  4. F. & D. Rentals, Inc. v. CommissionerUnited States Tax Court · 1965
  5. Holdcroft Transp. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1946

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