The U.S. Supreme Court case Commissioner of Internal Revenue v. Keystone Consolidated Industries, Inc., 1992 revolved around the issue of whether an employer's contribution to a pension plan should be considered as income for tax purposes when the funds are not vested or guaranteed to employees. The court ruled in favor of Keystone Consolidated Industries, stating that such contributions do not constitute taxable income until they become irrevocably vested and nonforfeitable rights for employees under ERISA (Employee Retirement Income Security Act). This ruling was based on the premise that if these contributions were taxed before vesting, it would potentially discourage employers from establishing beneficial pension plans due to increased financial burdens.

In the dissenting opinion for Commissioner of Internal Revenue v. Keystone Consolidated Industries, Inc., Justice Blackmun disagreed with the majority's interpretation of Section 412(c)(2) of the Internal Revenue Code. He argued that this section should be interpreted to mean that an employer can only take a deduction for contributions made to a pension plan if those contributions are necessary to fund future benefits under the plan. In his view, allowing employers to deduct excess contributions would undermine Congress' intent in enacting Section 412(c)(2), which was designed to prevent employers from using their pension plans as tax shelters by making excessive contributions and then recouping them later without having paid taxes on them. Furthermore, he believed that such an interpretation could potentially lead to abuse by encouraging companies with overfunded pensions plans not only keep contributing but also claim deductions for these unnecessary payments.