Square D Company and Subsidiaries - Page 23

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          of related administrative costs) for the VEBA Trust year ended              
          November 30, 1986, and $11,193,974 (plus $731,907 of related                
          administrative costs) for the VEBA Trust year ended November 30,            
          1987.  The parties have stipulated that the additions to the                
          account limit for CIBU's, if not based on the safe harbor limits,           
          are $7,619,925 (plus $395,683 of related administrative costs)              
          and $5,290,729 (plus $261,232 of related administrative costs)              
          for the VEBA Trust years ended November 30, 1986 and 1987,                  
          respectively.                                                               
               Petitioner contends that the phrase in section 419A(c)(1)              
          "Except as otherwise provided in this subsection" means that                
          any other provision, i.e., section 419A(c)(5), is outside of, and           
          not subject to, the general requirement of section 419A(c)(1).              
          Accordingly, petitioner contends that, because section 419A(c)(5)           
          does not require that the account limit be reasonable, no such              
          requirement exists.  Petitioner also argues that the safe harbor            
          limits allow taxpayers to avoid the burden of demonstrating that            
          additions to the account limit are reasonable, because the only             
          way to show reasonableness would be to obtain an actuarial                  
          certification.                                                              
               We disagree with petitioner.  Although Congress sought to              
          reduce the cost of compliance by allowing certain additions to              
          the account limit to be made without having to incur the cost of            
          obtaining actuarial certification, a taxpayer must still show               
          that the additions to the account limit for CIBU's during the tax           




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