CORNELL-YOUNG COMPANY, Plaintiff-Appellant,
v.
UNITED STATES of America, Defendant-Appellee.
MACON PRESTRESSED CONCRETE COMPANY, Plaintiff-Appellant,
v.
UNITED STATES of America, Defendant-Appellee.
United States Court of Appeals, Fifth Circuit.https://leagle.com/images/logo.png
December 5, 1972.
December 5, 1972.
Attorney(s) appearing for the Case
Charles M. Cork, Sr., Charles M. Cork, Jr., George T. Williams, Macon, Ga., for plaintiff-appellant.
William J. Schloth, U. S. Atty., Macon, Ga., Scott P. Crampton, Asst. Atty. Gen., Tax Div., Meyer Rothwacks, Atty., Michael L. Paup, Dept. of Justice, Washington, D. C., for defendant-appellee.
Before COLEMAN, GOLDBERG, and GODBOLD, Circuit Judges.
United States Court of Appeals, Fifth Circuit.
GOLDBERG, Circuit Judge:
"Neither the [Internal Revenue] Code nor Regulations issued thereunder contain any requirement that as a condition precedent for obtaining the tax benefits incident and pertaining to qualified employees [pension] plans an advance ruling as to initial qualification or termination must be obtained from the Internal Revenue Service. Such an advance ruling is issued only on request of a taxpayer and is not initiated by the Internal Revenue Service...
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