Romann v. Commissioner
United States Tax Court
The MEBA Plan, a collectively bargained, multiemployer pension plan, provided notice in an employee publication that the MEBA Plan was going to apply to the IRS for an advance determination that it continued to be a tax-qualified pension plan after adoption of certain plan amendments.
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The MEBA Plan, a collectively bargained, multiemployer pension plan, provided notice in an employee publication that the MEBA Plan was going to apply to the IRS for an advance determination that it continued to be a tax-qualified pension plan after adoption of certain plan amendments. P, a retiree receiving a pension under the MEBA Plan, received this notice and wrote to the IRS asserting that the MEBA Plan, after incorporation of the amendments, no longer would be tax- qualified. The IRS issued a favorable determination letter to the MEBA Plan. P filed a petition for declaratory judgment…
1Opinion of the Court
OPINION
Chabot, Judge:
This matter is before the Court on respondent Commissioner’s motion to dismiss for lack of jurisdiction. The issue for decision is whether petitioner is an “interested party” entitled to file a petition for declaratory judgment pursuant to section 7476(b)(1),1 with respect to the continuing qualification of the MEBA Pension Trust Regulations (hereinafter sometime referred to as the MEBA Plan), under subchapter D of chapter 1, sections 401-424. MEBA is an acronym for Marine Engineers’ Beneficial Association.
Background
This case was submitted for decision on the basis of an…
2Cases cited17 opinions
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