Estate of James F. Hall, Jr., Deceased, Harriet Hall, Executrix, and Harriet Nixon Hall - Page 3

                                        - 3 -                                         
          because it believed that the Plan was overfunded and that by                
          terminating the Plan, it would permit the company to distribute             
          Plan assets without violating new funding limits under the Tax              
          Reform Act of 1986.  However, the Plan assets were not completely           
          distributed until 1988.                                                     
               During 1987 and 1988, the IRS audited the Hadd-Too Plan.               
          During the course of this audit, Hadd-Too and Mr. Hall were                 
          represented by attorney Susan Foreman Jordan.  Ms. Jordan                   
          represented Mr. Hall and the company in pension matters from the            
          fall of 1984 until sometime after March 1989.  The IRS determined           
          that Mr. Hall engaged in prohibited transactions with respect to            
          certain Plan assets and that Mr. Hall was required to make                  
          restitution to the Plan or face liability for excise taxes.  The            
          IRS agreed to resolve the audit issues by having the Plan                   
          distribute all its assets to Mr. Hall, who was the sole                     
          participant in the Plan in 1988, rather than requiring Mr. Hall             
          to pay actual restitution or excise taxes.  The entire balance to           
          Mr. Hall's credit in the Plan was distributed to him in 1988.               
          The distribution consisted of cash and property in the amount of            
          $1,027,229.45.  At the time of this distribution, the Plan was              
          still a qualified plan within the meaning of section 401(a).                
               The Plan provided for the payment of retirement benefits to            
          Hadd-Too employees.  In addition to the payment of ordinary                 
          retirement benefits, the Plan contained the following provision             






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011