Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent issued a notice of deficiency to petitioner for excise taxes for fiscal years (ending June 30) 1983, 1984, 1985, 1986, 1987, and 1988. The notice of deficiency determined that two transfers of property by petitioner to its employees' pension plan, in satisfaction of petitioner's funding obligations, were prohibited transactions under section 4975.
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