Ronald R. Pawlak, P.C. v. Commissioner
United States Tax Court
P, a corporation, established profit-sharing and pension plans (Plans) in July 1970. In September 1984, P received favorable determination letters from R stating that P's Plans were qualified under sec. 401(a), I.R.C. The letters also stated that R had reserved judgment on the Plans' compliance with the Deficit Reduction Act of 1984 (DEFRA), Pub.
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P, a corporation, established profit-sharing and pension plans (Plans) in July 1970. In September 1984, P received favorable determination letters from R stating that P's Plans were qualified under sec. 401(a), I.R.C. The letters also stated that R had reserved judgment on the Plans' compliance with the Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98-369, 98 Stat. 494. In October 1993, R mailed P final revocation letters stating that the favorable determination letters were retroactively revoked for the Plans' years ended June 30, 1986, 1987, 1988, and 1989. R determined from an examination…
1Opinion of the Court
RONALD R. PAWLAK, P.C., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Ronald R. Pawlak, P.C. v. Commissioner
Docket Nos. 1745-94R, 1749-94R1
United States Tax Court
T.C. Memo 1995-7; 1995 Tax Ct. Memo LEXIS 7; 69 T.C.M. (CCH) 1603;
January 10, 1995, Filed
Decisions will be entered for respondent.
P, a corporation, established profit-sharing and pension plans (Plans) in July 1970. In September 1984, P received favorable determination letters from R stating that P's Plans were qualified under sec. 401(a), I.R.C. The letters also stated that R had reserved judgment on the Plans' compliance…
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