CUDAHY, Circuit Judge.
Cardiovascular surgeon Dr. Harry A. Wellons, 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. The IRS disallowed the deductions on the grounds that the payments were made to a deferred compensation plan within the meaning of 26 U.S.C. § 404(a) and...
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