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.Page: 1 2 3 4 5 6 7 8 9 10 Next
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