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$44,063,665 deducted by petitioner on Schedule M-1 related to
covered services performed after the end of TYE 8801.
For taxable years after TYE 8801, petitioner reported
deductions based upon contributions attributable to covered
services performed during the taxable year (but not previously
deducted for tax purposes), as well as contributions attributable
to covered services performed after the close of the taxable
year, where the contributions were made before the filing date
for petitioner's Federal income tax return. In contrast to TYE
8801, for taxable years before and after TYE 8801, petitioner
deducted only contributions calculated with reference to covered
services performed over a 12-month period. At no time did
petitioner file a Form 3115 (Application for Change in Accounting
Method) concerning the method used to arrive at its deduction for
contributions to the plans claimed on its return for TYE 8801.
In her notice of deficiency, respondent disallowed the
$44,179,950 Schedule M-1 adjustment upon determining that
petitioner could not properly deduct contributions attributable
to covered services performed after the close of the taxable year
as so-called grace period contributions. Respondent did not
disallow the $57,607,463 deduction representing contributions
made by petitioner to the plans attributable to covered services
performed during TYE 8801.
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Last modified: May 25, 2011