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161168P.pdf   05/09/2017  DNA Pro Ventures, Inc., etc.  v.  CIR
   U.S. Court of Appeals Case No:  16-1168
   The United States Tax Court   
   [PUBLISHED] [Loken, Author, with Murphy and Kelly, Circuit Judges] 
   Tax Case - Qualified Employee Stock Ownership Plan. Disqualification of 
   tax-exempt status of Employee Stock Ownership Plan for exceeding the 
   I.R.C. sec. 415 contribution limit is affirmed. The Tax Court did not 
   clearly err in basing its findings of fact in the IRS's uncontested 
   Explanation of Items that the Plan was not a section 401(a) qualified plan 
   and the Commissioner did not abuse his discretion in disqualifying the 
   Plan.