- 13 - were to be applied to months ending on or before February 2, 1986. For purposes of paying benefits and plan expenses, all contributions to each CBA Plan are pooled and no distinction is made between contributions for any specific time period or contributions made by any particular employer. Petitioner consulted with the firm of Price Waterhouse regarding the acceleration of deductions for post-tax yearend contributions to collectively bargained defined benefit pension plans. The parties stipulated that during the relevant period, Price Waterhouse was engaged in marketing that type of acceleration to certain clients and other employers that were making required contributions to multiemployer defined benefit pension plans. By section 601(a) and (b)(1) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2085, 2249, the top corporate tax rate was reduced from 46 percent to 34 percent for tax years beginning on or after July 1, 1987. See S. Rept. 99-313, (1986) 1986-3 C.B. (Vol. 3), 219, 220-221; H. Conf. Rept. 99-841 (Vol. 2), at II-59 (1986). Income in taxable years that included July 1, 1987 (other than as the first day of such year) was subject to blended rates. Id.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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