Legal Opinion

Plastic Engineering & Mfg. Co. v. Commissioner

United States Tax Court

Decided June 30, 1982No. Docket No. 6724-78Published

P was incorporated on Sept. 15, 1974, and elected to report its income on a fiscal year basis ending Jan. 31. On Sept. 30, 1974, P adopted a defined benefit pension plan with a plan year ending Sept. 30. Prior to Jan. 31, 1975, P made contributions to the plan equal to the normal cost of funding the 12-month plan year beginning Sept. 30, 1974. P claimed deductions for the full amount of its contributions on its return for its first, short taxable year covering from Sept. 15,…

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P was incorporated on Sept. 15, 1974, and elected to report its income on a fiscal year basis ending Jan. 31. On Sept. 30, 1974, P adopted a defined benefit pension plan with a plan year ending Sept. 30. Prior to Jan. 31, 1975, P made contributions to the plan equal to the normal cost of funding the 12-month plan year beginning Sept. 30, 1974. P claimed deductions for the full amount of its contributions on its return for its first, short taxable year covering from Sept. 15, 1974, through Jan. 31, 1975. Held, the requirement that services actually be rendered concerns only the fact of…

1Opinion of the Court

Plastic Engineering & Manufacturing Co., Petitioner v. Commissioner of Internal Revenue, Respondent

Plastic Engineering & Mfg. Co. v. Commissioner

Docket No. 6724-78

United States Tax Court

78 T.C. 1187; 1982 U.S. Tax Ct. LEXIS 71; 78 T.C. No. 83; 3 Employee Benefits Cas. (BNA) 1791;

June 30, 1982, Filed

Decision will be entered under Rule 155.

P was incorporated on Sept. 15, 1974, and elected to report its income on a fiscal year basis ending Jan. 31. On Sept. 30, 1974, P adopted a defined benefit pension plan with a plan year ending Sept. 30. Prior to Jan. 31, 1975, P made contributions to the…

2Cases cited5 opinions

  1. United States v. CalderonSupreme Court of the United States · 1954
  2. United States v. SanchezSupreme Court of the United States · 1950
  3. Bianchi v. CommissionerUnited States Tax Court · 1976
  4. La Mastro v. CommissionerUnited States Tax Court · 1979
  5. Plastic Engineering & Mfg. Co. v. CommissionerUnited States Tax Court · 1982

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