Robert D. Booth and Janice Booth, et al. - Page 80

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          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 their                   









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