Booth v. Commissioner
United States Tax Court
Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. L. 98-369, secs. 511(a), 512(a), 98 Stat. 494, 854, 862, limit an employer's deductions for contributions made to a welfare benefits fund for employees. These limitations do not apply to a welfare benefits fund that is part of a "10 or more employer plan" described in sec. 419A(f) (6), I.R.C.
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Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. L. 98-369, secs. 511(a), 512(a), 98 Stat. 494, 854, 862, limit an employer's deductions for contributions made to a welfare benefits fund for employees. These limitations do not apply to a welfare benefits fund that is part of a "10 or more employer plan" described in sec. 419A(f) (6), I.R.C. Under the Prime Plan, in which Ps participated, each participating employer made a one-time, nonrevertible contribution to a single trust, equal to the amount necessary to fund the dismissal wage and death benefits of its…
1Opinion of the Court
ROBERT D. BOOTH AND JANICE BOOTH, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Booth v. Commissioner
Docket Nos. 2544-94, 2545-94, 2546-94, 5754-94, 5755-94, 5893-94, 9229-94, 9230-94
United States Tax Court
108 T.C. 524; 1997 U.S. Tax Ct. LEXIS 32; 108 T.C. No. 25; 21 Employee Benefits Cas. (BNA) 1494;
June 17, 1997, Filed
Decision will be entered for petitioners in docket Nos. 2544-94, 2546-94, 5755-94, 5893-94, and 9229-94; decision will be entered for respondent with respect to the deficiencies and for petitioners with respect to the penalties in docket Nos. 2545-94 and…
2Cases cited39 opinions
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- Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
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