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SUTHERLAND v. COMMISSIONER

Docket No. 9971-78R.

78 T.C. 395 (1982)

ROBERT D. SUTHERLAND, D.B.A. SUTHERLAND ROCKY MOUNTAIN LUMBER COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 9, 1982.

Attorney(s) appearing for the Case

George T. Morton, for the petitioner.

Stephen J. Morrow, for the respondent.

OPINION

WILBUR, Judge:

Respondent determined that during 1976 petitioner's annuity and money-purchase plans failed to meet the minimum participation standards contained in section 410. See sec. 401(a)(3).1 Pursuant to section 7476, petitioner has invoked the jurisdiction of this Court for a declaratory judgment that its plans satisfy such qualification requirements.2 The issues for our decision...

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