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Internal Revenue Service
Number: 200243001 Release Date: 10/25/2002 Index Number: 1042.00-00
Department of the Treasury
Washington, DC 20224
Person to Contact: Telephone Number: Refer Reply To:
June 5, 2002
LEGEND Taxpayer A Taxpayer B Taxpayer C Company = = = =
Date L Date M State X Dear :
= = =
This responds to your letter requesting a ruling on behalf of the above-named taxpayer on the application of section 1042 to certain transactions described below. According to the facts submitted and the representations made, the Company is a domestic C corporation and has no stock outstanding that is readily tradable on an established securities market. The Company maintains the ESOP which qualifies under section 401(a) and meets the requirements of section 4975(e)(7) of the Code.
Prior to Date L, Taxpayers A and B owned stock in the Company. None of this was acquired a distribution from plan described section 401(a) or ...