-32-
procedure is to be entitled to receive a copy of the
determination issued by the Service in connection with the
proceeding. If the employee questions a Service
determination with respect to the qualification of a
particular plan, he may petition the Tax Court to issue a
declaratory judgment as to the status of the plan.
The committee believes that this procedure is desirable
because it will permit all interested parties to the
controversy (the Government, the trustee, the employer, and
his employees) to have an opportunity to participate in the
administrative determination of the matter and to have an
opportunity to contest the Service determination of the
matter.
S. Rept. 93-383, 113 (1973), 1974-3 C.B. (Supp.) 80, 192. On
September 18, 1973, the Senate began floor debate on S. 4, and
adopted as a substitute, an amendment which embodied an agreement
between leaders of the Senate Finance Committee and the Senate
Labor and Public Welfare Committee. The substitute embodied
elements of S. 4, as reported, and S. 1179, as reported. In
particular, section 601(a) of the substitute includes precisely
the same language as section 601(a) of S. 1179, relating to
declaratory judgment actions brought by employees.
On September 19, 1973, after the Senate completed action on
further amendments to S. 4, the Senate took up H.R. 4200, a bill
previously passed by the House of Representatives, and added the
language of S. 4, as amended, as an amendment at the end of H.R.
4200. 119 Cong. Reg. 30416 (1973). The Senate then passed H.R.
4200, as thus amended. 119 Cong. Rec. 30428 (1973).
As a result of the foregoing, the language of H.R. 4200 as
amended and passed by the Senate, insofar as it related to
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