Houg v. Commissioner

General Controls Co. had instituted a profit-sharing retirement income plan for its employees under which it was obligated to contribute 15 percent of its net operating profits to the "Company Fund" portion of the plan. General Controls merged with another corporation and ceased to exist. All of its assets were transferred to the other corporation and all of its employees became employees of the new corporation. The profit-sharing plan of the transferor corporation was amended, effective on the date of the merger, so that any employee of General Controls Co. could receive total distribution…