Susan Jane Hoyez, C.P.A. - Page 2




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          Petitioner resided in Portland, Oregon, at the time the petition            
          was filed.                                                                  
               This case was submitted fully stipulated under Rule 122, and           
          the facts may be summarized as follows.  Petitioner is a                    
          certified public accountant doing business as a sole                        
          proprietorship.  On November 22, 1993, petitioner adopted a                 
          revised money purchase pension plan (the Plan) effective January            
          1, 1993.  The Plan was adopted to meet the requirements of the              
          Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2085, and                 
          subsequent legislation including the Omnibus Budget                         
          Reconciliation Act of 1993, Pub. L. 103-66, 107 Stat. 312.                  
               The Plan is a qualified plan within the meaning of section             
          401.  The Plan is subject to the funding requirements of section            
          412, and petitioner is an employer within the meaning of section            
          412.  Both petitioner and the Plan have taxable years ending                
          December 31.  Petitioner made contributions to the Plan for 1993            
          of $1,491 and $4,145 on April 28 and October 3, 1994,                       
          respectively.                                                               
               Respondent determined that the October 3, 1994, contribution           
          was made after the period allowed by section 412(c)(10)(B).  As a           
          consequence the Plan failed to meet the minimum funding standard            
          for 1993.  Respondent also determined that petitioner failed to             
          file a Form 5330, Return of Excise Taxes Related to Employee                
          Benefit Plans.  Respondent issued a notice of deficiency for 1993           






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