Jack R. Mendenhall Corp. v. Commissioner
United States Tax Court
On Sept. 27, 1967, petitioner executed a profit-sharing agreement and petitioner and the trustee of the plan executed a trust agreement for the plan.
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On Sept. 27, 1967, petitioner executed a profit-sharing agreement and petitioner and the trustee of the plan executed a trust agreement for the plan. The plan was to be effective for petitioner's taxable year ending Sept. 30, 1967. On Feb. 20, 1973, petitioner first applied to the District Director of Internal Revenue for a determination letter that the plan qualified under sec. 401, I.R.C. 1954. After the District Director held that the plan was not qualified, petitioner amended the plan to be effective retroactively and the District Director issued a favorable determination letter on Apr.…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in the petitioner’s Federal corporate income taxes for the taxable years ending September 30, 1971, and September 30, 1972, in the respective amounts of $4,844.73 and $1,775.36. The sole issue for decision is whether petitioner’s profit-sharing plan qualified under section 4011 of the Internal Revenue Code of 1954 for the taxable years ending September 30, 1971, and September 30, 1972.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and attached exhibits are incorporated herein.
The Jack R. Mendenhall Corp.…
2Cases cited1 opinion
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