A.C. Green Electrical Contractors, Inc. - Page 11

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               We note that with regard to qualified plans, a QJSA is                 
          generally defined in the Code and regulations in terms of a                 
          reduced joint and survivor annuity.  See sec. 417(b); sec.                  
          1.401(a)-11(b)(2), Income Tax Regs.                                         
               Petitioner has not identified any plan language which                  
          logically establishes a subsidized joint and 100-percent survivor           
          annuity as a form of benefit for Rozenblatt and Jakubowicz.                 
               For the above reasons, we agree with respondent's                      
          interpretation of the language of the plans, and we conclude that           
          under the plans, Rozenblatt and Jakubowicz receive retirement               
          benefits in the form of joint and 100-percent survivor annuities            
          that have the same present value as single life annuities for the           
          life of each participant or reduced joint and 100-percent                   
          survivor annuities.  Accordingly, the portion of petitioner's               
          contributions to the plans that exceed the costs of funding                 
          retirement benefits for Rozenblatt and Jakubowicz in the form of            
          reduced joint and 100-percent survivor annuities was properly               
          disallowed by respondent.                                                   
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                           under Rule 155.                            









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