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GROSS DISTRIBUTING COMPANY v. COMMISSIONER

Docket No. 5988-81R.

43 T.C.M. 1357 (1982)

T.C. Memo. 1982-264

Gross Distributing Company v. Commissioner.

United States Tax Court.

Filed May 17, 1982.

Attorney(s) appearing for the Case

Martin Welenken and Judith A. Rosenberg, 730 W. Water St., Louisville, Ky., for the petitioner. Robert E. Touchton, for the respondent.

Memorandum Opinion

SIMPSON, Judge:

The petitioner has instituted this action pursuant to section 7476 of the Internal Revenue Code of 19541 for declaratory judgment relating to the qualification of pension and profit-sharing plans. We must decide whether the petitioner's plans qualified during the years in issue and, if not, whether the Commissioner's retroactive revocation of the qualification of the plans constituted an abuse...

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