Ed Thielking, Inc. v. Commissioner

T.C. Memo. 2020-5

UNITED STATES TAX COURT ED THIELKING, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1870-16R. Filed January 9, 2020. Michael A. Gilmer, for petitioner. Pamela J. Sewell, David Conrad, and Shawn P. Nowlan, for respondent. MEMORANDUM OPINION MARVEL, Judge: Petitioner seeks a declaratory judgment under section 74761 that the Ed Thielking, Inc. Employee Stock Ownership Plan (ESOP) and the 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court…