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CALFEE, HALTER & GRISWOLD v. COMMISSIONER

Docket Nos. 43655-85R-43659-85R, 2753-86R-2756-86R.

88 T.C. 641 (1987)

CALFEE, HALTER & GRISWOLD, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 23, 1987.

Attorney(s) appearing for the Case

Thomas A. Jorgensen and Mary M. Reil, for the petitioners.

Steven W. Ianacone, for the respondent.

WILLIAMS, Judge:*

The Commissioner determined that the trusts created or organized as part of petitioners' pension plans or profit-sharing plans were not qualified trusts within the meaning of section 401(a).2 Petitioners seek a declaratory judgment of this Court pursuant to section 7476 that the trusts constitute qualified trusts within the meaning of section 401(a).3

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