Dr. Erol Bastug, Inc. v. Commissioner
United States Tax Court
In October 1981, P executed pension and profit sharing plans modeled after those of a previous employer which had received a favorable determination from the IRS in 1969. P's plans were not submitted to the IRS for initial qualification until March 1984, after the IRS notified P that its 1981 profit sharing plan return was under examination.
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In October 1981, P executed pension and profit sharing plans modeled after those of a previous employer which had received a favorable determination from the IRS in 1969. P's plans were not submitted to the IRS for initial qualification until March 1984, after the IRS notified P that its 1981 profit sharing plan return was under examination. After restructuring the plans in accordance with suggestions of the IRS, P received a favorable determination for its plans for post 1983 years. P received a final adverse determination letter for its plans for 1981-1983. Having exhausted its…
1Opinion of the Court
DR. EROL BASTUG, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dr. Erol Bastug, Inc. v. Commissioner
Docket No. 45933-85R.
United States Tax Court
T.C. Memo 1989-262; 1989 Tax Ct. Memo LEXIS 262; 57 T.C.M. (CCH) 562; T.C.M. (RIA) 89262; 11 Employee Benefits Cas. (BNA) 1120;
May 30, 1989.
In October 1981, P executed pension and profit sharing plans modeled after those of a previous employer which had received a favorable determination from the IRS in 1969. P's plans were not submitted to the IRS for initial qualification until March 1984, after the IRS notified P that its 1981…
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