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WINGER'S DEPARTMENT STORE v. COMMISSIONER

Docket No. 10866-81.

82 T.C. 869 (1984)

WINGER'S DEPARTMENT STORE, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 4, 1984.

Attorney(s) appearing for the Case

Michael P. Casterton and Alvin R. Wohl, for the petitioner.

Ray K. Kamikawa, for the respondent.

STERRETT, Judge:

Respondent, in his notice of deficiency dated April 6, 1981, determined deficiencies of $22,704, $25,505, $22,943, and $15,302 in petitioner's Federal income taxes for the years 1976, 1977, 1978, and 1979, respectively. After concessions by the parties, the issue remaining for decision is whether the trust created under petitioner's pension plan for employees was a qualified trust within the meaning...

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