Howard E. Clendenen - Page 4




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                    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            




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