Memorandum Opinion
NIMS, Chief Judge:
Respondent determined that the Mortenson Roofing Profit-Sharing Trust (plan) is not exempt from taxation under section 501(a) for plan years ending on and after October 31, 1984, on the ground that the plan does not comply with the requirements of section 401(a). (Section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure...
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