107 T.C. No. 1
UNITED STATES TAX COURT
LUCKY STORES, INC., AND SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4446-93. Filed August 6, 1996.
P made contractually required monthly
contributions to 29 collectively bargained defined
benefit pension plans. For its fiscal year ended
February 2, 1986, P obtained an extension of the time
within which to file its Federal income tax return to
October 15, 1986. On its return P deducted, in
addition to the 12 monthly contributions based on
employee hours worked during the fiscal year, monthly
contributions based on hours worked during months
intervening between the last day of the fiscal year and
the extended due date of the return. Held: the
contributions based on hours worked after the close of
the fiscal year and before October 15, 1986, were not
on account of P's February 2, 1986 fiscal year, as
required by sec. 404(a)(6), I.R.C., and are therefore
not deductible in that year.
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