Memorandum Opinion
NIMS, Judge:
Respondent determined that Advisors Pension Services, Inc., HR-10 Executive Plan and Trust for Stephen Kellough (the Plan) was not a qualified plan under section 401(a), since petitioner was not an "employer" under section 401(c). Respondent further determined that the trust established in order to fund the Plan would no longer be exempt from Federal income tax under section 501(a). Petitioner challenges respondent's determinations...
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