Sheppard & Myers, Inc. v. Commissioner
United States Tax Court
Petitioner adopted a pension plan in 1970. On Mar. 5, 1971, the District Director, Internal Revenue Service, Philadelphia, Pa., issued a favorable determination letter with respect to the initial qualification of the plan. The plan has not been amended since initial qualification.
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Petitioner adopted a pension plan in 1970. On Mar. 5, 1971, the District Director, Internal Revenue Service, Philadelphia, Pa., issued a favorable determination letter with respect to the initial qualification of the plan. The plan has not been amended since initial qualification. Upon audit, for the year ended Dec. 31, 1972, respondent concluded that the plan, in its operation, failed to meet the requirements of sec. 401(a), I.R.C. 1954. On Jan. 29, 1976, respondent mailed a notice of his determination that the plan failed to meet the requirements of sec. 401(a), I.R.C. 1954, to petitioner.…
1Opinion of the Court
OPINION
Wiles, Judge:
Petitioner adopted a pension plan in 1970. On March 5, 1971, the District Director, Internal Revenue Service, Philadelphia, Pa., issued a favorable determination letter with respect to the initial qualification of the plan. The plan has not been amended since initial qualification. Upon audit, for the year ended December 31, 1972, respondent concluded that the plan, in its operation, failed to meet the requirements of section 401(a).1 On January 29, 1976, respondent mailed a notice of his determination that the plan failed to meet the requirements of section 401(a) to…
2Cited by12 opinions
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- Alves v. CommissionerUnited States Tax Court · 1982
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