PER CURIAM.
This is an appeal from a decision of the Tax Court upholding an income tax deficiency for the years 1976 and 1977 upon a finding that contributions by the petitioner to its pension and profit-sharing trust should be disallowed. The Tax Court held that the petitioner did not sustain its burden of showing that its trust was a qualified plan and that assets of the trust were used exclusively for the benefit of its employees.
The dispute arose when...
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