MILLER & KEARNEY v. COMMISSIONER

Docket No. 4260-76R.

36 T.C.M. 81 (1977)

T.C. Memo. 1977-16

Miller & Kearney, a California Professional Corporation (formerly Miller, Jennings & Kearney) v. Commissioner.

United States Tax Court.

Filed January 26, 1977.


Attorney(s) appearing for the Case

Robert E. Noel, for the petitioner. Harry Morton Asch and Vernon R. Balmes, for the respondent.


Memorandum Opinion

FAY, Judge:

This case is before us on respondent's motion to dismiss for lack of jurisdiction.

Petitioner is a California professional corporation engaged in the practice of law. In November 1973 petitioner adopted an employee stock bonus plan, with a plan year extending from February 1 to January 31. On December 12, 1973, an application for a determination letter was filed by petitioner with respondent. The application requested...

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