BING MANAGEMENT COMPANY, INC. v. COMMISSIONER

Docket No. 9096-75.

36 T.C.M. 1633 (1977)

T.C. Memo. 1977-403

Bing Management Company, Inc. v. Commissioner.

United States Tax Court.

Filed November 21, 1977.


Attorney(s) appearing for the Case

Alvin R. Wohl, 901 H St., Sacramento, Calif., for the petitioner. Bryce A. Kranzthor, for the respondent.


Memorandum Findings of Fact and Opinion

QUEALY, Judge:

This proceeding involves a determination of deficiency in income tax against petitioner in the amount of $25,076.48 for the fiscal year ended March 31, 1973. As a result of concessions made by the parties, the only issue remaining for decision is whether petitioner's pension and profit-sharing plans qualify under section 401 or section 405.1

Findings of Fact

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