Orthopedics International, Ltd., P.S. v. Commissioner
Case Details
- Judge(s)
- Sterrett
- Status — whether other courts must follow this ruling
- Published
- Procedural Posture — the stage the case had reached
- appeal
Related Laws
Claim Types
Outcome
The Second Circuit reversed the district court's dismissal of negligence and failure-to-warn claims and reserved decision by certifying two questions of state law to the Supreme Court of Connecticut regarding federal preemption of product liability claims involving a medical device.
Excerpt
Petitioner had both a qualified profit-sharing plan and a qualified money purchase pension plan. In a pre-ERISA taxable year, petitioner attempted to deduct as a sec. 404(a)(7), I.R.C. 1954, carryover deduction amounts in excess of any amount allowable as a deduction under sec. 404(a)(1)(C) and (a)(1)(D). Held: No sec. 404(a)(7) carryover deduction was created by petitioner's contributions to its pension plan in excess of the limits set in sec. 404(a)(1). During the years in issue the second sentence of sec. 404(a)(7) provided a carryover deduction only for amounts otherwise allowable as deductions which had been disallowed in a previous year under the first sentence of that paragraph.
What This Ruling Means
This summary was generated to explain the ruling in plain English and is not legal advice.
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