Beals Bros. Management Corp. - Page 2

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          ended June 30, 1987, and subsequent years.  Respondent also                 
          determined that the trust that constituted a part of the MGMT               
          ESOP was consequently not exempt from taxation under section                
          501(a) for the same years.  Following these determinations,                 
          respondent revoked a favorable determination letter previously              
          issued to petitioner with respect to the MGMT ESOP.                         
               Petitioner timely invoked the Court’s jurisdiction under               
          section 7476.  Petitioner seeks a declaratory judgment that                 
          respondent erred in his determination that the MGMT ESOP does not           
          meet the requirements of section 401.  We hold that respondent              
          did not err as averred.                                                     
                                  FINDINGS OF FACT2                                   
               When the petition was filed, petitioner maintained a                   
          principal place of business in Des Moines, Iowa.  Petitioner was            
          incorporated to provide management and advisory services to Beals           
          Brothers Manufacturing Co. (MFG).  At all relevant times,                   
          petitioner’s officers and directors consisted of one or more of             
          the following persons:  Richard Faye Beals, Donald Wayne Beals,             
          Fay J. Beals (collectively, the Bealses), and Gayle D. Isaac                
          (collectively with the Bealses, the management officers).                   
          Petitioner had no other officers or employees during that time.             

               2 Some of the facts have been stipulated and are so found.             
          The exhibits accompanying the stipulation of facts and the                  
          stipulated administrative record are incorporated by this                   

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