MEMORANDUM OPINION
HAMBLEN, Judge:
This is an action for a declaratory judgment regarding the qualification of petitioner's defined benefit plan and trust. This case was submitted on the administrative record, pursuant to Rule 217. Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.
On April 3, 1997, respondent issued a final nonqualification...
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