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referred to in paragraph (1), to any individual
designated under regulations prescribed by the
Secretary as a representative of such employee),
no proceeding may be initiated under this section
by any person unless the pleading is filed before
the ninety-first day after the day after such
notice is mailed to such person (or to his
designated representative, in the case of an
employee).
(c) Retirement Plan.--For purposes of this section,
the term "retirement plan" means--
(1) a pension, profit-sharing, or stock bonus
plan described in section 401(a) or a trust which is
part of such a plan, or
(2) an annuity plan described in section 403(a).
Thus, following the passage of ERISA, our authority to make a
declaratory judgment concerning the qualification of a retirement
plan, or whether the qualification of a retirement plan is
revoked, is subject to five jurisdictional limitations set forth
in section 7476(b). See also Rule 210(c). Any of these
limitations, if not met, will prevent us from making a
declaratory judgment and will result in a dismissal of the
underlying petition. Id.; McManus v. Commissioner, 93 T.C. 79,
84 (1989).
We are concerned with the limitation in section 7476(b)(5),
namely, the time for bringing an action for a declaratory
judgment. Our decision turns on the text of this section, which,
if plain and unambiguous, is the answer to our inquiry. To the
extent that we can understand and apply the plain meaning of
unambiguous statutory text, we shall do so. Garcia v. United
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