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more of its voting stock was owned directly or indirectly by
persons described in section 4975(e)(2)(A), (B), (C), (D), or
(E). Sec. 4975(e)(2)(G).
1. Whether the Garrahan Agency Provided Services to the
Plan
Petitioners contend that the Garrahan Agency was not a
disqualified person under section 4975(e)(2)(B) because it did
not provide services to the plan. Petitioners claim that
Travelers provided services to the plan. We disagree. The
Garrahan Agency serviced and processed the life insurance
policies purchased by the FUH plan. The Garrahan Agency is thus
a disqualified person under section 4975(e)(2)(B).
2. Whether Petitioner Owned 50 Percent or More of the
Garrahan Agency
Petitioners argue that the Garrahan Agency is not a
disqualified person under section 4975(e)(2)(G) because 50
percent or more of its voting stock was not owned by a
disqualified person described in section 4975(e)(2)(A), (B), (C),
(D), or (E). We disagree.
A disqualified person includes any corporation 50 percent or
more of which is owned directly or indirectly by persons
described in section 4975(e)(2)(A), (B), (C), (D), or (E). Sec.
4975(e)(2)(G). For purposes of section 4975(e)(2)(G)(i), an
individual is deemed to own stock owned directly or indirectly by
or for his family. Secs. 267(c), 4975(e)(4). For purposes of
section 4975(e)(4), the term "family" includes the individual's
spouse. Sec. 4975(e)(6). Thus, any interest in the Garrahan
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