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BEALS BROS. MANAGEMENT CORP. v. COMMISSIONER

Docket No. 10871-99R.

82 T.C.M. 485 (2001)

T.C. Memo. 2001-234

Beals Bros. Management Corp. v. Commissioner.

United States Tax Court.

Filed September 6, 2001.

Attorney(s) appearing for the Case

David R. Rhein, for the petitioner. Michael J. Roach and James S. Stanis, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

Respondent determined that the employee stock ownership plan (MGMT ESOP) operated by petitioner did not meet the requirements of section 401(a)(3) or (4)1 for its plan year ended June 30, 1987, and subsequent years. Respondent also determined that the trust that constituted a part of the MGMT ESOP was consequently not exempt from taxation under section 501(a) for the same years...

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