Parker-Hannifin Corporation - Page 26

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               Under section 419A(a), “‘qualified asset account’ means any            
          account consisting of assets set aside to provide for the payment           
          of” certain benefits.  In order to qualify as a deductible                  
          contribution to a welfare benefit fund under section 419(a),                
          petitioner’s contribution must not exceed the qualified cost of             
          the fund, i.e., the qualified direct costs plus any qualified               
          asset account.  Qualified asset accounts are generally subject to           
          an account limit, which for these purposes is the amount                    
          reasonably and actuarially necessary to fund claims incurred but            
          unpaid as of the close of the taxable year in which the                     
          contribution is made, and the related administrative costs.  For            
          petitioner’s 1987 year, no benefits were paid out of the VEBA               
          Trust, and, thus, no qualified direct costs were incurred.                  
          Petitioner argues that the $2.5 million contribution for                    
          long-term disability is a qualified asset account and is                    
          deductible.                                                                 
               The parties disagree as to the meaning of the phrase “assets           
          set aside” in the definition of qualified asset account.                    
          Petitioner contends that the phrase does not require that a                 
          “reserve” be established, pointing out that “reserve” is used               
          only in the context of postretirement benefits in section 419A.             
          Respondent argues that petitioner must actually set aside the               
          assets to include them in the qualified asset account and to                
          deduct the contribution.                                                    






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Last modified: May 25, 2011