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HOWARD E. CLENDENEN, INC. v. COMMISSIONER

Docket No. 18155-96R.

76 T.C.M. 394 (1998)

T.C. Memo. 1998-318

Howard E. Clendenen, Inc. v. Commissioner.

United States Tax Court.

Filed September 3, 1998.

Attorney(s) appearing for the Case

Paul F. Christoffers, for the petitioner. Lawrence H. Ackerman, for the respondent.

MEMORANDUM OPINION

TANNENWALD, Judge:

This is an action for a declaratory judgment regarding the qualification of petitioner's employee stock ownership plan and trust. On May 22, 1996, respondent issued a final revocation letter to petitioner stating that the Howard E. Clendenen, Inc. Employee Stock Ownership Plan (the ESOP) failed to meet the requirements of section 401(a)1 for the...

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