Parker-Hannifin Corporation - Page 28

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               As in the case of the postretirement benefits, petitioner              
          did not disclose the establishment of reserves for long-term                
          disability benefits in its financial reporting for its 1987 year.           
          Only those employees involved in the implementation of the VEBA             
          were informed about the existence of the VEBA.  By making the               
          contribution for long-term disability benefits, petitioner                  
          received a substantial tax savings.  Petitioner’s treasurer                 
          estimated in a July 1987 letter that the 1987 contribution would            
          be depleted in 12 to 18 months after the VEBA was established.              
          The 1987 contribution was depleted by the second month of                   
          petitioner’s 1989 year.  Petitioner made no contribution for                
          long-term disability benefits that were incurred but unpaid                 
          during its 1988 year, and, in the following years, petitioner               
          contributed to the VEBA through monthly contributions                       
          approximating the benefits that were paid.  No indication of                
          reserves was shown on petitioner’s Form 1024, Application for               
          Recognition of Exemption.  Again, while disclosure is not                   
          required by the applicable Code and regulations, the lack of                
          disclosure, along with petitioner’s other actions regarding the             
          VEBA Trust, shows that petitioner did not accumulate assets in              
          the VEBA Trust for the purpose of setting aside assets for the              
          payment of future long-term disability benefits that were                   
          incurred but unpaid.                                                        
               We cannot conclude that these assets were set aside for the            
          above-stated purposes, and, thus, we need not address the                   




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