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BORUTA v. COMMISSIONER

Docket No. 11341-87R.

55 T.C.M. 670 (1988)

T.C. Memo. 1988-172

Peter M. Boruta, M.D., P.C. v. Commissioner.

United States Tax Court.

Filed April 25, 1988.

Attorney(s) appearing for the Case

Kenneth M. Wissbrun, 407 Travelers Twr., Southfield, Mich., for the petitioner. Paul S. Horn and Will E. McLeod, for the respondent.

Memorandum Opinion

STERRETT, Chief Judge:

This case is before the Court on a petition for declaratory judgment pursuant to section 7476.1 The issue presented for our decision is whether petitioner's pension plan and trust constituted a qualified trust under section 401(a) for plan years beginning on or after May 1, 1982.

The parties submitted this case on a fully stipulated administrative record pursuant to Rule 122,...

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