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judgment pursuant to section 7476(b)(1)1 with respect to the
continuing qualification of the Maritime Association
International Longshoremen's Retirement Plan Number 002 (MAIL
Plan).
Background
Petitioner is a participant in the MAIL Plan. Before its
approval for tax-exempt status under sections 401 and 501, on
May 21, 1997, the board of trustees for the MAIL Plan filed an
Application for Determination for Collectively Bargained Plan
with the Internal Revenue Service (IRS). The MAIL Plan
administrator issued a letter to all contributing employers on
July 8, 1997, asking that the Notification to Interested Parties
with respect to the application filed by the MAIL Plan be posted
at the principal places of employment and where notices
concerning employee-management issues are usually posted.
Petitioner found out about the pending application from his
employer's human resources office and filed comments with the
District Director, which were sent on August 4, 1997, opposing
approval of the plan.
1Unless otherwise indicated, all chapter, subchapter, and
section references are to chapters, subchapters, and sections of
the Internal Revenue Code of 1986, as in effect at the time the
petition herein was filed. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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