Joseph R. Rollins - Page 11

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          the Plan filed any tax returns or information returns for any               
          taxable periods.                                                            
          4.  U.S. Department of Labor                                                
               On April 16, 2002, respondent sent a letter to the                     
          Department of Labor notifying the Department of Labor that                  
          respondent was contemplating adjusting petitioner’s section 4975            
          tax liability.  This letter was sent pursuant to section 3003(a)            
          of the Employee Retirement Income Security Act of 1974 (29 U.S.C.           
          1203(a)), Pub. L. 93-406, 88 Stat. 829, 998 (ERISA ‘74).  On May            
          8, 2002, respondent sent another letter to the Department of                
          Labor, stating that the matter was now before respondent’s                  
          Appeals Office and asking for a response within 60 days.                    


























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