Connecticut Mutual Life Insurance Company and Consolidated Subsidiaries - Page 22

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          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.            




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