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LUDDEN v. COMMISSIONER

Docket No. 2992-76.

68 T.C. 826 (1977)

ALLEN LUDDEN AND BETTY WHITE LUDDEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 31, 1977.

Attorney(s) appearing for the Case

Barney B. Shiotani and Joel M. Butler, for the petitioners.

Richard W. Kennedy, for the respondent.

OPINION

SCOTT, Judge:

Respondent determined a deficiency of $26,917 in petitioners' Federal income tax for the calendar year 1972. The sole issue for decision is whether amounts contributed on behalf of each petitioner to pension and profit-sharing plans of their wholly owned corporation should be included in petitioners' taxable income because of failure of the plans to qualify under section 401(a), I.R.C...

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