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by October 15, 1990. N.L. Booth made this contribution, without
interest, on January 30, 1991. N.L. Booth's 1989 tax return
claimed a $100,000 deduction for accrued contributions owed the
Trust.
N.L. Booth's 1990 tax return claimed a $56,739 deduction for
accrued contributions owed the Trust. On February 14, 1992, N.L.
Booth paid Firstar Metropolitan Bank & Trust (Firstar) $55,000 of
this amount; N.L. Booth never paid the remaining $1,739.
Generally, the $55,000 contribution was applied as follows:
(1) An increase in DWB's resulting from the change in the accrual
percentage, (2) an increase in vesting, and (3) the cost of a
death benefit.
In all, N.L. Booth executed the following Adoption
Agreements relating to its participation in the Prime Plan:
Date effective 07/31/90 07/31/90 01/01/91 07/31/90
Dismissal wage benefit percentage 4.196 2.84 6.54 4.196
Years of service 10 10 10 10
Vesting schedule 4/40 4/40 4/40 4/40
Normal retirement age Same as 401(a) Same Same Same
Death benefit multiple 4.122 2.692 4.122 4.122
Date executed 07/31/90 07/31/90 07/30/91 10/01/91
D. Administration of N.L. Booth's Account in the Prime Plan
On August 12, 1991, IFTI forwarded the 1990 annual report
for N.L. Booth's account in the Prime Plan to John Booth. The
report pertained only to N.L. Booth's Employee Group. The report
included an actuarial valuation signed by Deloitte & Touche and
provided the following calculations of vested DWB's:
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