- 28 - 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 thePage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011