Parker-Hannifin Corporation - Page 19

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          “account limit” under section 419A(c) is only a mathematical                
          computation that limits the deduction, not a requirement that a             
          segregated reserve be included in the welfare benefit fund.                 
               However, the VEBA Trust did not retain even general assets             
          that were sufficient to fund the reserves claimed by petitioner.            
          Thus, petitioner's position has the same shortcomings as the                
          position that the Court considered and rejected in General Signal           
          Corp. & Subs. v. Commissioner, 103 T.C. 216 (1994).  In General             
          Signal, the taxpayer corporation argued that section 419A(c)(2)             
          did not require the establishment of a funded reserve in order              
          for an amount to be included in the account limit.  Id. at 240.             
          Because of the taxpayer corporation’s “vehement assertion” that             
          “reserve funded” did not have a commonly understood meaning, the            
          Court looked to the legislative history of section 419A(c)(2) for           
          guidance and determined “that Congress intended section                     
          419A(c)(2) to permit the accumulation of funds for purposes of              
          funding postretirement benefits.”  Id.                                      
               The legislative history of section 419A states, in part:               
                    Prefunding of life insurance, death benefits, or                  
               medical benefits for retirees.--The qualified asset                    
               account limits allow amounts reasonably necessary to                   
               accumulate reserves under a welfare benefit plan so                    
               that the medical benefit or life insurance (including                  
               death benefit) payable to a retired employee during                    
               retirement is fully funded upon retirement.  These                     
               amounts may be accumulated no more rapidly than on a                   
               level basis over the working life of the employee, with                
               the employer of each employee.  * * *  The conferees                   
               intend that the Treasury Department prescribe rules                    
               requiring that the funding of retiree benefits be based                
               on reasonable and consistently applied actuarial cost                  
               methods, which take into account experience gains and                  



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