- 12 -
regardless of which amounts we use, the annual additions
allocated to Mr. Clendenen during each of the plan years 1986,
1987, 1989, 1990, and 1991, exceed the section 415 limits.
Petitioner has not argued or established that any corrective
measures were taken to reduce these additions. See sec. 1.415-
6(b)(6), Income Tax Regs.
We hold that the trust is not a qualified trust under
section 401(a) beginning with the plan year 1986.
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011