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RALPH GANO MILLER CORP. v. COMMISSIONER

Docket No. 9631-78R.

76 T.C. 433 (1981)

RALPH GANO MILLER, A PROFESSIONAL LAW CORPORATION, A CALIFORNIA CORPORATION (FORMERLY MILLER & KEARNEY), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 17, 1981.

Attorney(s) appearing for the Case

Steven K. Ewald and Robert K. Butterfield, for the petitioner.

Claudia Jane Kelly, for the respondent.

OPINION

STERRETT, Judge:

This is an action for declaratory judgment brought by petitioner Ralph Gano Miller, a Professional Law Corporation (formerly Miller & Kearney), pursuant to section 7476, I.R.C. 1954. Respondent has determined that Ralph Gano Miller, a Professional Law Corporation Stock Bonus Plan and Trust (formerly Miller & Kearney Stock Bonus Plan and Trust) failed to qualify as a stock bonus plan under the requirements of section...

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