Square D Company and Subsidiaries - Page 28

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          direct cost for the year, plus any contributions to a QAA                   
          reasonably necessary to fund CIBU's and/or to provide a reserve             
          for postretirement medical or life insurance benefits.  Secs. 419           
          and 419A.  The taxpayer in General Signal increased its VEBA                
          contributions during 1986 by making additions to a QAA, although            
          it did not intend the VEBA trust to establish a reserve for                 
          postretirement benefits or accumulate assets for purposes of                
          funding a reserve.  The taxpayer's additional QAA contributions             
          during 1986 and 1987 totaled $63,300,000.  The VEBA trust's                 
          balance increased by only $8,782,003 between November 30, 1986,             
          and November 30, 1988, while its financial statements showed                
          expenses for retiree liabilities of only $8,813,000.                        
          Accordingly, of the $63,300,000 contributed to fund a reserve, at           
          least $45,700,000 ($63,300,000 less $8,782,003 and $8,813,000)              
          was used to pay active employee welfare benefits during 1987 and            
          1988.  Additionally, the taxpayer made no disclosures on its                
          financial reports of the establishment or maintenance of reserves           
          for postretirement medical or life insurance benefits, nor did it           
          make any disclosure to its employees or their unions of the                 
          establishment or maintenance of such reserves.  Finally, the                
          taxpayer's Form 1024, containing projected yearend balances for             
          1986 through 1988, did not show reserves established for any                
          purpose.  On the basis of all of the facts and circumstances, we            
          concluded that the VEBA trust did not accumulate assets for the             






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