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On or about November 6, 2002, an Employee Plans Specialist
at the IRS sent a letter to Hercules informing it that she had
been assigned to evaluate and review the determination letter
application that it had submitted. On or about January 18, 2003,
petitioner received a letter from the IRS that acknowledged the
receipt of his comments concerning the request for determination
that had been submitted by Hercules. On or about January 21,
2003, Hercules received a letter from the IRS informing it that
the IRS had received comments from an interested party concerning
the request for determination that had been submitted by
Hercules.
On or about March 3, 2003, the IRS issued a favorable
determination letter to Hercules with respect to the amended
plan. This determination letter was applicable to the amendments
that Hercules had executed on January 28, 2002. In this letter,
the IRS stated that the changes that were made to the
qualification requirements by the following public laws had been
considered in reaching its determination: The Uruguay Round
Agreements Act, Pub. L. 103-465, 108 Stat. 4809; the Uniformed
Services Employment and Reemployment Rights Act of 1994, Pub. L.
103-353, 108 Stat. 3149; the Small Business Job Protection Act of
1996, Pub. L. 104-188, 110 Stat. 1755; the Taxpayer Relief Act of
1997, Pub. L. 105-34, 111 Stat. 788; the Internal Revenue Service
Restructuring and Reform Act of 1998, Pub. L. 105-206, 112 Stat.
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Last modified: May 25, 2011