Connecticut Mutual Life Insurance Company and Consolidated Subsidiaries - Page 17

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          necessary business expenses pursuant to section 162(a).  Our                
          review of the plan documents in question indicated that the                 
          reversion of any assets from the VEBA was clearly prohibited.               
               Finally, in Moser v. Commissioner, supra, we disagreed with            
          the Commissioner's argument that the corporation's contribution             
          was excessive, and, therefore, the corporation should not be                
          allowed a deduction for the full amount.  The corporation's                 
          $200,000 contribution was based on calculations made by a                   
          financial consultant to ascertain the full amount of all                    
          potential severance benefits and the life insurance and medical             
          insurance premiums that were necessary to fund death, disability,           
          and accident benefits for 1 year.  We found that the                        
          corporation's original $200,000 contribution had "provided for              
          full funding of the severance benefits and generated income                 
          sufficient to fund the annual costs of providing VEBA benefits -            
          no more, no less."  Moser v. Commissioner, supra.                           
               In Schneider v. Commissioner, T.C. Memo. 1992-24, we held              
          that a personal service corporation was entitled to deduct                  
          contributions made to three employee welfare benefit plans                  
          established to provide death, disability, and termination                   
          benefits to employees and educational benefits to the children of           
          eligible employees.  The Commissioner argued that the                       
          contributions at issue were capital expenditures because they               
          created a benefit for the taxpayer that lasted substantially                
          beyond the taxable year in which the contributions were made.               




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