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CONNECTICUT MUT. LIFE INS. CO. & SUBS. v. COMMR.

Docket No. 4291-94.

106 T.C. 445 (1996)

CONNECTICUT MUTUAL LIFE INSURANCE COMPANY & CONSOLIDATED SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 26, 1996.

Attorney(s) appearing for the Case

Matthew J. Zinn, J. Walker Johnson, and Tracy L. Rich, for petitioner

Jill A. Frisch and Randall P. Andreozzi, for respondent.

RUWE, Judge:

Respondent determined a deficiency of $7,372,712 in petitioner's 1985 Federal income tax. The sole issue for decision is whether petitioner is entitled to a 1985 deduction for its $20 million contribution to a voluntary employees' beneficiary association (VEBA) trust. In order to prevail, petitioner must establish that the $20 million contribution was an ordinary and necessary business expense under section 162(a).1

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