United States Tax Court December 27, 1945, Docket Nos. 8765, 8766 (Anderson v. Commissioner)

OPINION.

Arundell, Judge-.

Petitioner contends that the trusts to which Pacolet and Monarch made payments during the taxable years involved formed a part of a “pension * * * plan of an employer for the exclusive benefit of some or all of his employees” within the meaning of section 165 of the Internal Revenue Code,2 as amended by the Revenue Act of 1939.