Connecticut Mutual Life Insurance Company and Consolidated Subsidiaries - Page 1

                                   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.                                           
                                                                                     









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