- 18 - 1.419A-2T, Temporary Income Tax Regs., 50 Fed. Reg. 27428 (July 3, 1985). Postretirement Benefits Section 419A(c)(2) provides for an additional reserve for postretirement medical and life insurance benefits: (2) Additional reserve for post- retirement medical and life insurance benefits.--The account limit for any taxable year may include a reserve funded over the working lives of the covered employees and actuarially determined on a level basis (using assumptions that are reasonable in the aggregate) as necessary for-- (A) post-retirement medical benefits to be provided to covered employees (determined on the basis of current medical costs), or (B) post-retirement life insurance benefits to be provided to covered employees. Petitioner included $10,779,650 in its 1987 contribution for postretirement benefits for retirees. The 1987 contribution included $16,133,508 for postretirement benefits for active employees. Respondent disallowed the deduction of these contributions on petitioner’s fiscal 1987 Federal income tax return. Petitioner argues that section 419A(c)(2) allows a reserve funded over the working lives of covered employees for postretirement benefits to be included in the account limit without requiring that specific assets be set aside or that a separate account be created. Petitioner contends that thePage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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