T.C. Memo. 2001-234
UNITED STATES TAX COURT
BEALS BROS. MANAGEMENT CORP., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10871-99R. Filed September 6, 2001.
David R. Rhein, for petitioner.
Michael J. Roach and James S. Stanis, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Respondent determined that the employee stock
ownership plan (MGMT ESOP) operated by petitioner did not meet
the requirements of section 401(a)(3) or (4)1 for its plan year
1 Unless otherwise indicated, section references are to
sections of the Internal Revenue Code in effect for the years in
issue. Rule references are to the Tax Court Rules of Practice
and Procedure.
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