68 T.C. No.
1 opinion
Certain individuals worked daily in the offices of the two petitioner professional corporations, but the workers' records were maintained and their paychecks were issued by a separate payroll… Held: the office personnel are employees of the professional corporations and such corporations' respective pension and profit-sharing plans fail to qualify under sec. 401, I.R.C. 1954, because such plans fail to satisfy the coverage requirements of sec. 401(a)(3)(A), I.R.C. 1954.