- 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., EmployeePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011