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SQUARE D CO. & SUBSIDIARIES v. COMMISSIONER

Docket Nos. 15047-94, 4991-95.

109 T.C. 200 (1997)

SQUARE D COMPANY AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 9, 1997.

Attorney(s) appearing for the Case

Robert H. Aland, Gregg Douglas Lemein, Taylor S. Reid, Tamara L. Frantzen, Maura Ann McBreen, and Brian K. Wydajewski, for petitioner in docket No. 15047-94.

Robert H. Aland, Gregg Douglas Lemein, Neal J. Block, Frederick Edward Henry III, Maura Ann McBreen, Tamara L. Frantzen, Taylor S. Reid, Brett L. Gold, and Brian K. Wydajewski, for petitioner in docket No. 4991-95.

Lawrence C. Letkewicz and Randall P. Andreozzi, for respondent.

OPINION

WELLS, Chief Judge:

The instant cases were consolidated for purposes of trial, briefing, and opinion (hereinafter referred to as the instant case). The instant case is before the Court on the parties' cross-motions for partial summary judgment. We must decide whether petitioner's contribution to its trust created as part of its voluntary employees' beneficiary association (VEBA) plan for the 1986 taxable year is deductible. Specifically, we...

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