- 7 - account was fully liquidated. Petitioner did not receive Schedules K-1, Partner's Share of Income, Credits, Deductions, Etc., from Estes Co. from 1981 through 1989 or 1990. Petitioner employed Mr. Estes under the management contract from September 1980 through September 1985. He did not serve as an officer or director of petitioner during those years. On September 30, 1986, petitioner's board of directors voted to terminate the management contract effective December 31, 1986. Formal notice of termination provided to Estes Co. was dated November 1, 1986. At the time the management contract was terminated, all of the employees originally listed in the contract had retired from or otherwise terminated their employment with petitioner except for Mr. Shedd, and he was preparing to retire from petitioner. The Pension Plan On September 18, 1980, petitioner adopted a defined benefit pension plan (the plan), effective September 20, 1979. Petitioner amended and restated the plan on December 5, 1985, effective for plan year ending September 19, 1985, and respondent issued a favorable determination letter as to the qualification of the plan and its related trust as restated (hereinafter collectively referred to as plan) on July 8, 1987. The determination letter cautioned: "Continued qualification of the plan will depend on its effect in operation under its present form."Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011