Professional & Executive Leasing, Inc., an Idaho Corporation, Petitioner v. Commissioner Internal Revenue Service

U.S. Court of Appeals, Ninth Circuit · Decided 1988-12-06

Cited by 137 later decision(s) in our corpus · see the citation network in Lexace

From the opinion

BOOCHEVER, Circuit Judge: Professional Executive Leasing, Inc. (PEL) appeals a decision by the tax court in its action for declaratory relief. The tax court determined that PEL’s retirement plans did not qualify under I.R.C. § 401 because the plans covered individuals who were not employees of PEL. Thus, the requirement of § 401(a)(2) that a qualifying plan be for the “exc…

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