- 4 -
11. For the taxable year ended June 30, 1989, the
parties agree that the issues designated “ESOP Contribution
to Non-Qualified Plan” and “Deductible Dividends to ESOP” in
the notice of deficiency are consequential to the issue of
plan qualification in related docket 18155-96 “R”.
Respondent and the corporation signed this stipulation of settled
issues.
Mr. Clendenen’s stipulation of settled issues provided in
part:
9. For the taxable year 1987, the parties agree that
the issue designated “Employer Contribution” and “Deferred
Compensation” in the notice of deficiency are consequential
to the issue of plan qualification in related docket 18155-
96 “R”.
10. For the taxable year 1988, the parties agree that
this stipulation resolves all issues in dispute.
11. For the taxable year 1989, the parties agree that
the remaining issue, designated “Employer Contribution” in
the notice of deficiency is consequential to the issue of
plan qualification in related docket 18155-96 “R”.
Respondent and Mr. Clendenen signed this stipulation of settled
issues.
On February 13, 1998, the corporation and Mr. Clendenen also
each filed a Stipulation To Be Bound. The corporation’s
stipulation to be bound stated that the only remaining issues in
dispute relate to the plan qualification as asserted in
paragraphs 4(a) and (b) in the petition. Further, the
corporation’s stipulation to be bound provided in part:
2. The adjustments in respondent’s notice of
deficiency relating to the issues or items asserted in
paragraphs 4(a) and (b) of the petition, as specified in the
preamble, shall be determined by the resolution of the
qualified status of the Howard E. Clendenen, Inc., Employee
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011