Lansons, Inc., Cross-Appellant v. Commissioner of Internal Revenue, Cross-Appellee

RONEY, Circuit Judge:

Taxpayer claims income tax deductions for the years 1969-71 for contributions to a profit-sharing trust, charging that the Commissioner abused his discretion in revoking retroactively an earlier letter ruling that the trust was “qualified” within the meaning of section 401(a) of the Internal Revenue Code. 1 Agreeing with the Tax Court’s determination, 69 T.C. 773, that the Commissioner’s retroactive revocation was an abuse of discretion, we affirm.

After some ten years in the men’s retail clothing business, Lansons, Inc. sought to reduce the high turnover of employees by…