Wasatch Chemical Co. v. Commissioner
United States Tax Court
Petitioner, a corporation on an accrual basis of accounting, executed and delivered its promissory notes, payable 5 years after date, to an employees' profit-sharing pension trust. Held, the contribution of such notes does not constitute a deductible payment within the meaning of sec. 404, I.R.C. 1954.
1Opinion of the Court
OPINION.
Fay, Judge:
The Commissioner determined deficiencies in petitioner’s income tax for the taxable years 1954, 1955, and 1956 in the amounts of $19,999.75, $21,534.64, and $19,085.54, respectively. At the hearing of this case the petitioner conceded the deficiency for the year 1954, thereby leaving for our consideration only the years 1955 and 1956. The basic issue to be decided is whether the petitioner is entitled to deductions for contributions allegedly paid to its employees’ profit-sharing pension trust in 1955 and 1956.
All of the facts have been stipulated, are so found, and are…
2Cases cited9 opinions
- Spiegel v. CommissionerUnited States Tax Court · 1949
- Time Oil Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Burson v. HuntingtonMichigan Supreme Court · 1870
- City of New Port Richey v. Fidelity & Deposit Co. of MarylandCourt of Appeals for the Fifth Circuit · 1939
- Sachs v. Commissioner of Internal Revenue. Slaymaker Lock Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
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3Cited by16 opinions
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- Don E. Williams Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1975
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