a revenue ruling or revenue procedure, is not the law; it merely represents respondent’s view of the law. See Stubbs, Overbeck & Associates, Inc. v. United States, 445 F.2d 1142, 1146-1147 (5th Cir. 1971). 4 We observe that after the years in issue Congress added sec. 4980(d), in the Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, sec. 12002(a), 104 Stat. 1388, 1388-562, which imposes a 50-percent tax on an employer reversion unless the employer establishes a “qualified replacement retirement plan”. For a new plan to be qualified, it must have as active participants at least 95 percent of the active participants in the terminated plan who remain as employees of the employer after the termination. Sec. 4980(d)(2)(A). 5 See Estate of Young v. Commissioner, 81 T.C. 879 (1983) (<HOLDING>). Believing it appropriate for the Tax Court to
holding that failure to make any tax payment despite having resources sufficient to pay all or a substantial portion of tax liability constitutes evasion holding that state legislature should determine whether to cure discriminatory tax by enforcing tax as to all or forgiving tax in its entirety holding that this court does not have jurisdiction over tax claims for declaratory or equitable relief holding that federal courts do not have jurisdiction over a suit to enjoin a tax lien holding this court generally lacks jurisdiction over the sec 6651a2 addition to tax for failure to pay tax