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liabilities or determinations of costs of providing
pension benefits under the plan and were made by a
person competent to make such determinations in
accordance with reasonable assumptions as to mortality,
interest, etc., and correct procedures relating to the
method of funding. For example, a trust has
accumulated assets of $1,000,000 at the time of
liquidation, determined by acceptable actuarial
procedures using reasonable assumptions as to interest,
mortality, etc., as being necessary to provide the
benefits in accordance with the provisions of the plan.
Upon such liquidation it is found that $950,000 will
satisfy all of the liabilities under the plan. The
surplus of $50,000 arises, therefore, because of the
difference between the amounts actuarially determined
and the amounts actually required to satisfy the
liabilities. This $50,000, therefore, is the amount
which may be returned to the employer as the result of
an erroneous actuarial computation. If, however, the
surplus of $50,000 had been accumulated as a result of
a change in the benefit provisions or in the
eligibility requirements of the plan, the $50,000 could
not revert to the employer because such surplus would
not be the result of an erroneous actuarial
computation. [Emphasis added.]
“Actuarial errors” refer to clerical or mathematical
mistakes regarding actuarial assumptions and methods in
determining the future costs and liabilities required to meet a
plan’s funding. See Holland v. Valhi Inc., 22 F.3d 968, 972
(10th Cir. 1994). Petitioner argues that his 1984 decision to
assign his benefits to GCI was tantamount to actuarial error. We
disagree.
The amount of petitioner’s benefits which he attempted to
assign was part of the benefits which actuarial assumptions
addressed since the Plan’s inception. In accordance with the
example in section 1.401-2(b)(1), Income Tax Regs., upon
liquidation of the Plan, there were sufficient assets to meet the
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