- 31 - As discussed infra, section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), effectively denies the prefunding of claims by using differing taxable year ends. In an internal memorandum dated April 23, 1986, petitioner recognized that that regulation could close the "loophole created by the statute's ambiguity." During 1986, petitioner increased its section 419A account limit by allegedly creating a reserve for PRMB's under section 419A(c)(2). Wyatt, petitioner's actuary, calculated that the present value of petitioner's PRMB's, as of December 1, 1986, for retirees was $20,446,059, and for current active employees was $46,699,569, the deductible portion of which was $4,945,000. Accordingly, in Wyatt's view the total deductible cost of PRMB's for petitioner's tax year ending December 31, 1986, was $25,391,059. The associated administrative expenses were $1,650,419, which is 6.5 percent of the deductible PRMB's, and when they are added to the cost of the PRMB's, the total is $27,041,478. On December 30, 1986, petitioner contributed $27 million to the VEBA Trust. That contribution was the only one made to the VEBA Trust during the 1986 calendar year. The balance of the VEBA Trust on December 31, 1986, was $35,058,670. During the 1987 Plan year, the VEBA Trust paid benefit claims, including related expenses, of $31,572,854. During the 1987 Plan year, only $2,787,000 was paid by the VEBA Trust for benefit claims ofPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
Last modified: May 25, 2011