| 1973 - 384 էջ
...contribution deductible without regard to this subparagraph which the total prevented contribution bear» to the total current and accumulated earnings or profits...purposes of paragraphs (1), (2), and (3), a taxpayer on toe accrual basis shall be deemed to have made a payment on the last day of the year of accrual If... | |
| 1974 - 396 էջ
...plans. In the taxable year when paid, if the plan Is not one Included In paragraph (1), (2), or (3), U the employees' rights to or derived from such employer's...compensation Is paid. (6) Taxpayers on accrual basis. Por purposes of paragraphs (1), (2), and (3), a taxpayer on the accrual basis shall be deemed to have... | |
| 1949 - 774 էջ
...subparagraphs of section 23 (p) (1 ) , they are deductible under subparagraph (D) to the extent that individual employees' rights to or derived from such employer's...the time the contribution or compensation is paid. As to what constitutes nonforfeitable rights of an employee, see §29.165-7. If an amount is accrued... | |
| United States. Tax Court - 1976 - 1210 էջ
...during the taxable years in question, provided for a deduction of contributions to nonqualified plans "if the employees' rights to or derived from such...compensation are nonforfeitable at the time the contribution * * * is paid." Nonforfeitability means that at the time of such contribution there is no contingency... | |
| Jacob Stewart Seidman - 2003 - 972 էջ
...(D) In the taxable year when paid, if the plan is not one included in paragraphs (A}, (B), or (C), if the employees' rights to or derived from such employer's...the time the contribution or compensation is paid. (E) For the purposes of subparagraphs (A), (B), and (C), a taxpayer on the accrual basis shall be deemed... | |
| 1967 - 340 էջ
...applying the limitations In this subparagraph. (B) Profit-sharing plan of affiliated group. In the cace of a profit-sharing plan, or a stock bonus plan in...(2), or (3), If the employees' rights to or derived Irom such employer's contribution or such compensation are nonforfeitable at the time the contribution... | |
| United States. Tax Court - 1962 - 1242 էջ
...the following limitations as to the amounts deductible in any year: • •••••• (5) OTHEB PLANS. — In the taxable year when paid, if the plan...the time the contribution or compensation Is paid. [Emphasis added.] Petitioner argues that "Insofar as Section 162 is concerned, the deduction, allowable... | |
| United States. Tax Court - 1963 - 1122 էջ
...••»••• (2) EUPOTEE8' ANNUITIES. • • * (3) STOCK BONUS AND PROFIT-SHARINO TRUSTS. — • •****• (5) OTHER PLANS. — In the taxable year when paid,...such employer's contribution or such compensation are non-foifeltable at the time the contribution or compensation Is paid. (6) TAXPAYERS ON ACCRUAL BASIS.... | |
| United States. Tax Court - 1966 - 678 էջ
...— • • • (3) STOCK BONUS AND PROFIT-SHARING TRUSTS. — • • • • •**•*• (5) OTHEB PLANS. — In the taxable year when paid. If the plan...to or derived from such employer's contribution or euch compensation are nonforfeitable at the time the contribution or compensation is paid. ' By the... | |
| 1976 - 412 էջ
...deductible under the preceding paragraphs. ( 5 ) Other plans. In the taxable year when paid, a the plan 1s not one included in paragraph (1), (2), or (3), if...nonforfeitable at the time the contribution or compensation 1s paid. (6) Taxpayers on accrual basis. For purposes of paragraphs (1), (2), and (3), a taxpayer on... | |
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