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RHOADES, McKEE, AND BOER v. U.S.

No. 1:91:CV:540.

822 F.Supp. 445 (1993)

RHOADES, McKEE, and BOER, a Michigan partnership; Dale W. Rhoades, Tax Matter Partner; Timothy Hillegonds, Partner; and Rhoades, McKee, Boer, Goodrich and Titta, a Michigan corporation, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, W.D. Michigan.

May 24, 1993.

Attorney(s) appearing for the Case

Dale W. Rhoades, Thomas P. Hogan, Robert C. Shaver, Jr., Rhoades, McKee, Boer, Goodrich, et al., Grand Rapids, MI, for plaintiffs.

Michael L. Schipper, Asst. U.S. Atty., John A. Smietanka, U.S. Atty., Grand Rapids, MI, George P. Eliopoulos, U.S. Dept. of Justice, Tax Div., Thomas J. Clark, Dept. of Justice, Tax Div., Washington, DC, for defendant.

OPINION

ENSLEN, District Judge.

Pursuant to Fed.R.Civ.P. 52(e), the Court enters the following Findings of Fact and Conclusions of Law in the above-captioned matter.

Findings of Fact

The conflict between the parties in this case revolves around a defined benefit plan ("the plan" or "the Rhoades plan"). The retirement plan in question was created in 1984 by the law firm Rhoades, McKee, Boer, Goodrich & Titta ("Rhoades,...

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