Efco Tool Co. v. Commissioner
United States Tax Court
Respondent on Mar. 9, 1982, simultaneously issued to petitioner a statutory notice of deficiency and a final revocation letter as to the qualified status of petitioner's profit-sharing plan. On Apr. 30, 1982, respondent issued to petitioner a final revocation letter as to petitioner's retirement pension plan. On June 15, 1982, petitioner filed one petition which was docketed as a request for redetermination, not as a declaratory judgment action.
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Respondent on Mar. 9, 1982, simultaneously issued to petitioner a statutory notice of deficiency and a final revocation letter as to the qualified status of petitioner's profit-sharing plan. On Apr. 30, 1982, respondent issued to petitioner a final revocation letter as to petitioner's retirement pension plan. On June 15, 1982, petitioner filed one petition which was docketed as a request for redetermination, not as a declaratory judgment action. Petitioner's attorney conceded that this Court lacks jurisdiction over the matter as to the statutory notice of deficiency and the first final…
1Opinion of the Court
Efco Tool Company, a Michigan Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Efco Tool Co. v. Commissioner
Docket No. 13380-82
United States Tax Court
81 T.C. 976; 1983 U.S. Tax Ct. LEXIS 4; 81 T.C. No. 62; 5 Employee Benefits Cas. (BNA) 1246;
December 15, 1983, Filed
Respondent on Mar. 9, 1982, simultaneously issued to petitioner a statutory notice of deficiency and a final revocation letter as to the qualified status of petitioner's profit-sharing plan. On Apr. 30, 1982, respondent issued to petitioner a final revocation letter as to petitioner's retirement pension plan.…
2Cases cited13 opinions
- Midland Mortg. Co. v. CommissionerUnited States Tax Court · 1980
- B.H.W. Anesthesia Foundation, Inc. v. CommissionerUnited States Tax Court · 1979
- Thompson v. CommissionerUnited States Tax Court · 1978
- BBS Associates, Inc. v. CommissionerUnited States Tax Court · 1980
- Gladstone Foundation v. CommissionerUnited States Tax Court · 1981
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