- 5 -
equaled $1,580,455 for 1991 and $1,853,529 for 1992.4
The amounts of assets that the Trust set aside as of the
close of the years at issue to provide for the payment of health
care benefits and reasonable costs of administration directly
connected with providing for the payment of such benefits were
$41,975,366 and $45,637,659, respectively.
The Trust’s account limit, as defined in section 419A(c),
for its qualified asset account, as defined in section 419A(a),
was $64,615,9365 for 1991 and $84,192,933 for 1992. The forego-
ing account limits for 1991 and 1992 included $53,313,236 and
$71,602,395, respectively, attributable to a reserve for post-
retirement medical benefits.
The Trust filed Forms 990, Return of Organization Exempt
From Income Tax (Form 990), and Forms 990-T, Exempt Organization
Business Income Tax Return (Form 990-T), in which it reported as
unrelated business income $1,851,399 and $1,155,793 of investment
4The costs for 1992 ($1,853,529) were paid first from in-
vestment income for that year.
5The parties stipulated that the Trust’s account limit for
1991, as defined in sec. 419A(c), was $65,652,991. However, that
stipulation is contrary to the record in this case. The record
establishes, and we have found, that that account limit was
$64,615,936. We may, and we shall in this instance, disregard a
stipulation between the parties where the stipulation is clearly
contrary to the facts established by the record. See Cal-Maine
Foods, Inc. v. Commissioner, 93 T.C. 181, 195 (1989).
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