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Nat'l Presto Indus., Inc. v. Comm'r of Internal Revenue

104 T.C. 559 (U.S.T.C. 1995)
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Nat'l Presto Indus., Inc. v. Comm'r of Internal Revenue

3 Citing cases

  1. Booth v. Commissioner of Internal Revenue

    108 T.C. 524 (U.S.T.C. 1997)   Cited 1 times

    As stated by the House Ways and Means Committee, in proposing a change to the prior law, In National Presto Indus., Inc. v. Commissioner, 104 T.C. 559 (1995), and General Signal Corp. v. Commissioner, 103 T.C. 216 (1994), supplemented by 104 T.C. 248 (1995), this Court addressed other issues under subpt. D. The committee has concluded that the favorable tax treatment of employer contributions to welfare benefit plans, as compared with employer payments of wages and salary, is inappropriate in view of the favorable tax treatment already provided to employees, i.e., the exclusion of many of these benefits from adjusted gross income.

  2. Booth v. Comm'r of Internal Revenue

    108 T.C. 524 (U.S.T.C. 1997)   Cited 1 times

    As stated by the House Ways and Means Committee, in proposing a change to the prior law, In National Presto Indus., Inc. v. Commissioner, 104 T.C. 559, 1995 WL 255900 (1995), and General Signal Corp. v. Commissioner, 103 T.C. 216, 1994 WL 450465 (1994), supplemented by 104 T.C. 248, 1995 WL 91537 (1995), this Court addressed other issues under subpart D. The committee has concluded that the favorable tax treatment of employer contributions to welfare benefit plans, as compared with employer payments of wages and salary, is inappropriate in view of the favorable tax treatment already provided to employees, i.e., the exclusion of many of these benefits from adjusted gross income.

  3. Wells Fargo & Co. v. Comm'r of Internal Revenue

    120 T.C. 69 (U.S.T.C. 2003)   Cited 6 times   1 Legal Analyses
    In Wells Fargo Company v. Commissioner of Internal Revenue, 120 T.C. No. 5, 120 T.C. 69, 2003 WL 301884 (U.S.Tax Ct. 2003), similar accounting rules were promulgated in 1990 for non-pension, post-retirement benefits in Statement of Financial Accounting Standards No. 106 (SFAS 106). Pursuant to SFAS 106, for accounting purposes, employers had to accrue the cost of future health care benefits to be paid to employees after retirement during the employment of the employees.

    We have previously held that the “funded” reserve in section 419A(c)(2) refers to an accumulation of assets and the funding of benefits. Natl. Presto Indus., Inc. v. Commissioner, 104 T.C. 559, 574, 1995 WL 255900 (1995). A “reserve funded over the working lives of the covered employees” “clearly evokes the gradual accumulation of funds measured with an eye toward complete funding at the time of retirement”.