United States Tax Court November 9, 2000, No. 21333-97 (Sherwin-Williams Co. Employee Health Plan Trust v. Commissioner)

lead-opinion

OPINION1

Chiechi, Judge:

Respondent determined the following deficiencies in the Federal income tax (tax) of The Sherwin-Wil-liams Co. Employee Health Plan Trust (trust):

Year Deficiency

$489,941 rH 05 05 I — I

339,924 <N 05 05 T — I

The issues for decision are:

(1) In determining for each year at issue the unrelated business taxable income (UBTl) of the trust under section