Memorandum Findings of Fact and Opinion
QUEALY, Judge:
This proceeding involves a determination of deficiency in income tax against petitioner in the amount of $25,076.48 for the fiscal year ended March 31, 1973. As a result of concessions made by the parties, the only issue remaining for decision is whether petitioner's pension and profit-sharing plans qualify under section 401 or section 405.
Findings of Fact
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