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monthly contribution amounts attributable to covered hours or
weeks worked between February 3, 1985 and February 2, 1986, and
also added the 8 monthly contributions attributable to covered
hours or weeks worked from February 3, 1986 through August 31,
1986 and made before October 15, 1986 (the date on which
petitioner filed its return for the Current Taxable Year). In
addition, as to certain of the CBA Plans and bargaining units,
the dates were February 3, 1986 through September 30, 1986, in
which case there were nine monthly contributions instead of
eight. Thus petitioner claimed a deduction for 19--in some cases
20--monthly contributions on the Current Taxable Year return.
For fiscal years ending after February 2, 1986, petitioner
did not deduct any amounts which had been previously deducted on
its Federal income tax return for any prior year. For fiscal
years ending after February 2, 1986, petitioner claimed a
deduction for no more than 12 monthly contributions in any such
fiscal year. The record does not disclose the number of monthly
contributions claimed by petitioner for deduction purposes on its
Federal income tax return for the taxable year next succeeding
the Current Taxable Year.
The $36,661,529 in dispute consists of $31,427,131 of
contributions to the Six Large CBA Plans, and $5,234,398 to the
19 smaller plans. In the notice of deficiency, respondent did
not disallow the 12 monthly contributions totaling $57,139,406
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