- 5 - deduction in 1985, and that the VEBA was not liquidated until 1998, Mr. Bush estimated that the present value of petitioner's tax savings on December 27, 1985, was $5,455,000. On December 24, 1985, petitioner established the Connecticut Mutual Life Insurance Company Holiday Pay Plan6 (holiday pay plan), and on December 27, 1985, petitioner established the Connecticut Mutual Life Insurance Company Employee Welfare Benefit Trust (referred to herein as VEBA II or VEBA II trust). Petitioner created the trust as a funding medium for its holiday pay plan. On or about December 27, 1985, petitioner contributed $20 million to the trust and deducted the entire contribution on its 1985 Federal income tax return as an ordinary and necessary business expense. The holiday pay plan and the VEBA II trust essentially provided for the following: 5(...continued) provided that no part of the net earnings of the employer inures (other than through such payments) to the benefit of any private shareholder or individual. Sec. 501(c)(9). On May 13, 1986, petitioner transmitted to the Internal Revenue Service a completed Form 1024 (Application for Recognition of Exemption Under Section 501(a) or for Determination Under Section 120) for the VEBA II trust. On Jan. 13, 1988, the IRS recognized the tax-exempt status of the VEBA II trust, determining that it qualified as a voluntary employees' beneficiary association pursuant to sec. 501(c)(9). 6Petitioner amended the holiday pay plan on Dec. 31, 1985.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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