Westchester Plastic Surgical Associates, P.C. - Page 3




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                                     Background                                       
               Petitioner was a corporation existing under the laws of the            
          State of New York.  At the time of the filing of its petition in            
          this case, petitioner's address was P.O. Box 852, Southampton,              
          New York.  Michael Morrissey (Morrissey) was the owner of all of            
          the outstanding shares of petitioner's stock from 1972 through              
          the years in issue.  Morrissey was also the president and                   
          secretary of petitioner from inception.                                     
               Petitioner adopted the Defined Benefit Plan effective as of            
          November 1, 1976.  The Defined Benefit Plan received a favorable            
          determination letter from the Internal Revenue Service dated                
          December 5, 1988.  Since its inception, Morrissey has always been           
          the sole trustee of the Trust and as such has exercised complete            
          control over the management and disposition of the Defined                  
          Benefit Plan assets.                                                        
               The Defined Benefit Plan ceased benefit accruals in 1990,              
          at which time all plan participants were 100 percent vested.  The           
          Defined Benefit Plan terminated pursuant to a resolution of                 
          petitioner's board of directors dated September 4, 1990, and                
          effective September 26, 1990.  When the Defined Benefit Plan                
          ceased benefit accruals and terminated in 1990, there were two              
          participants in addition to Morrissey.  These two participants              
          were paid their full benefits in 1990 when the Defined Benefit              
          Plan terminated.   With the payout to these two participants in             





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