- 3 - the parties' cross-motions for partial summary judgment. We must decide whether petitioner's contribution to its trust created as part of its voluntary employees' beneficiary association (VEBA) plan for the 1986 taxable year is deductible. Specifically, we must decide: (1) Whether petitioner is entitled to the safe harbor limits of section 419A(c)(5)(B)(i) and (ii)1 in computing the addition to the qualified asset account for medical, dental, and short-term disability (also referred to as accident and sickness) benefit claims and associated administrative costs pursuant to section 419A(c)(1); (2) whether petitioner's $27 million contribution to its VEBA trust during 1986 constituted "a reserve funded over the working lives of the covered employees" for postretirement medical benefits (PRMB's) within the meaning of section 419A(c)(2); and (3) whether the limitation of section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), is valid. Background Some of the facts and certain exhibits have been stipulated by the parties for the purpose of the instant motion. The stipulation of facts is incorporated in this Opinion by reference. When its petition was filed, petitioner's principal office was located in Palatine, Illinois. Petitioner is a 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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