- 80 - employers are subject to subpart D. Under section 419, each employer's deduction for its contribution to its separate plan is limited to the plan's "qualified cost" for the year, less the plan's after-tax income. Sec. 419(a), (b), and (c); see also National Presto Indus., Inc. v. Commissioner, 104 T.C. 559, 566-567 (1995). An employer's qualified cost equals the qualified direct cost for the taxable year, plus an addition to a qualified asset account. Sec. 419(c)(1). Respondent has proffered to the Court calculations of each corporation's qualified cost and allowable deduction with respect to its plan. These calculations show that Young & Young is entitled to deduct $11 for 1989, and that no other corporation is allowed a deduction with respect to its plan. Petitioners do not dispute the mechanics of respondent's calculations, and petitioners have not supplied the Court with alternative calculations of qualified cost. Petitioners' position, which we have rejected, is that the corporations can deduct their contributions in full. We have reviewed respondent's calculations, and we are satisfied that they are correct. Accordingly, we sustain respondent's determination that the corporations are not allowed any deduction for the subject years with respect to theirPage: Previous 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 Next
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