T.C. Memo. 1999-161
UNITED STATES TAX COURT
ROBLENE, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21576-95R. Filed May 13, 1999.
Paul M. Thielking, for petitioner.
Lawrence H. Ackerman, Judith M. Picken, and Gregory J.
Stull, for respondent.
MEMORANDUM OPINION
HAMBLEN, Judge: This is an action for a declaratory
judgment regarding the qualification of petitioner's employee
stock ownership plan and trust. On August 7, 1995, respondent
issued a final revocation letter to petitioner stating that the
Roblene, Inc. Employee Stock Ownership Plan (the ESOP) failed to
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