106 T.C. No. 27 UNITED STATES TAX COURT CONNECTICUT MUTUAL LIFE INSURANCE COMPANY AND CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4291-94. Filed June 26, 1996. P created a voluntary employees' beneficiary association (VEBA) trust designed to fund P's future holiday pay obligations to its employees. On or about Dec. 27, 1985, P contributed $20 million to the VEBA. This $20 million contribution significantly exceeded the amount of P's average annual holiday pay obligation, which was approximately $2 million. P deducted the entire $20 million contribution as an ordinary and necessary business expense on its 1985 Federal income tax return. Held: P's $20 million contribution to the VEBA in 1985 provided P with substantial future benefits. P is therefore not entitled to deduct its $20 million contribution in 1985. INDOPCO, Inc. v. Commissioner, 503 U.S. 79 (1992), applied.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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