Court of Appeals for the Seventh Circuit August 4, 1994, 93-2991, 93-2992 (Harry A. Wellons, Jr., M.D., S.C. v. Commissioner of Internal Revenue)

CUDAHY, Circuit Judge.

Cardiovascular surgeon Dr. Harry A Wel-lons, Jr. set up a severance pay plan for his employees in 1983. Dr. Wellons contributed $194,000 to the trust for the plan in 1984 and again in 1985, and deducted these amounts from his income taxes as a business expense under 29 U.S.C. § 162.