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references are to the Tax Court Rules of Practice and Procedure.
The use of the term “reserve” in this opinion is for convenience
and is not conclusive as to characterization for tax purposes.
After a concession by respondent, the issue for decision is
whether and to what extent, if any, Parker-Hannifin Corporation
may deduct $32,498,684 in contributions it made to a welfare
benefit trust on June 30, 1987.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated herein by this reference.1 At the time
the petition in this case was filed, Parker-Hannifin Corporation
had its principal place of business in Cleveland, Ohio.
Petitioner is an accrual basis taxpayer and files its
Federal income tax return on a fiscal year ending June 30.
Petitioner filed timely its Form 1120, U.S. Corporation Income
Tax Return, and an associated amended return, Form 1120X, for its
taxable year ended June 30, 1987, with the Internal Revenue
Service Center at Cincinnati, Ohio.
Petitioner and its subsidiaries are engaged in, among other
things, the design, manufacture, and marketing of components and
systems for builders and users of durable goods, including
1The stipulation contained objections to many documents
offered by respondent, and those objections were sustained during
trial. Nonetheless, respondent proposed findings and presented
arguments as if those documents were in evidence. Such conduct
makes our task more difficult and respondent’s brief less
reliable.
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