Engineered Timber Sales, Inc. v. Commissioner

Held, for calendar year 1974, petitioner's collection of written documents fails to create a qualified profit-sharing plan within the dimensions of sec. 401(a), I.R.C. 1954. Held, further, in 1974, these writings do not constitute a nonqualified profit-sharing plan within the meaning of secs. 401 through 415 of the Code. Held, further, section 401(b), as amended by the Employee Retirement Income Security Act of 1974, does not permit retroactive adoption of an original profit-sharing plan. Held, further, petitioner is not entitled in 1974 to a deduction under sec. 404(a) for contributions made…