Reed Smith Shaw & MClay, William J. Smith, Tax Matters Partner - Page 2

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             that was claimed on the partnership's 1986 return.  The                  
             amount of the deduction is the value of certain stock that               
             the partnership allegedly contributed to a defined benefit               
             plan for the benefit of one of its partners.  The sole                   
             issue for decision is whether the partnership is deemed to               
             have "paid" the alleged contribution of stock to the                     
             defined benefit plan on the last day of 1986, as provided                
             by section 404(a)(6), with the result that it is entitled                
             to deduct the value of the stock on its 1986 return under                
             section 404(a)(1).  Unless stated otherwise, all section                 
             references are to the Internal Revenue Code as in effect                 
             during the year in issue.                                                

                                 FINDINGS OF FACT                                     
                  Some of the facts have been stipulated by the parties               
             and are so found.  The stipulation of facts and attached                 
             exhibits are incorporated herein by this reference.  At the              
             time the instant petition was filed, the principal place of              
             business of the partnership, Reed Smith Shaw & McClay, was               
             located in Pittsburgh, Pennsylvania, and the tax matters                 
             partner worked and resided there.  The partnership reported              
             income and expenses on a calendar year basis and used the                
             cash receipts and disbursements method of accounting.                    








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