- 22 - employee was employed by petitioner on the working days immediately preceding and following the holiday. Thus, the prefunding of petitioner's future holiday pay obligations was inextricably linked to acquiring the future benefits that petitioner would reap from its employees' services in subsequent years. In Moser v. Commissioner, supra, the contribution was an amount that provided for full funding of the vested severance benefits. This funding also generated income sufficient to pay relatively small annual insurance premiums for other VEBA benefits. In Schneider v. Commissioner, supra, the taxpayer's contribution to each plan for a particular year related only to the year in which the payment was made. Petitioner's contribution, on the other hand, did not fund benefits that were already vested and was not calculated to fund benefits for a specific period. Petitioner established VEBA II to prefund its holiday pay obligations for many years, and the future benefits from this prefunding were far from incidental. Between 1986 and 1994, petitioner's annual holiday pay expenses covered by the plan ranged from approximately $1.5 million to $2.2 million. Petitioner's original $20 million contribution produced investment earnings sufficient to cover over 80 percent of these 12(...continued) from work policy". As a result, only 6 holidays are now covered under the holiday pay plan and funded through the VEBA II trust.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011