A private operating foundation is not liable for the 20% excise tax imposed on the reversion of an employee pension plan of a taxable corporation simply because it has incurred some unrelated business income tax during the years the plan was in effect, the Tax Court has held. The Tax Code provides that the tax is due on reversion of a qualified plan generally exempt under sections 401(a) or 403(a) of the Code, “other than a plan maintained by an employer if such employer has, at all times, been exempt from tax under subtitle A” of the Code. Subtitle A covers the exemption of exempt organizations including private foundations and other 501(c)(3) charities. Research Corporation terminated its...