Roblene, Inc. - Page 19




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          need not make any findings with respect to the exact figures,               
          however, for regardless of which amount we use, the annual                  
          additions allocated to Robert and Charlene Peers during each of             
          the plan years that ended July 31, 1987, through July 31, 1990,             
          clearly exceed the section 415 limitations.  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.           
          Consequently, we hold that the ESOP failed to meet the                      
          requirements of section 401(a) for the plan years beginning after           
          July 31, 1986, and that the related trust is not a qualified                
          trust under section 401(a) for the plan years beginning after               
          July 31, 1986.                                                              
                                                  Decision will be entered            
                                             for respondent.                          















               10(...continued)                                                       
          in his briefs, uses the $0 figure appearing on Robert and                   
          Charlene Peers' individual return.                                          




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