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retirees. The VEBA Trust's balance on November 30, 1987, was
$7,992,215.
Wyatt calculated that the present value of petitioner's
PRMB's, as of December 1, 1987, for retirees was $10,732,153, and
for current active employees was $23,766,492, the deductible
portion of which was $2,511,252, for a total deductible reserve
contribution of $13,243,405.
On December 29, 1987, petitioner made a $12,400,000
contribution to the VEBA Trust. During the 1988 Plan year, the
December 29, 1987, contribution, additional contributions made
during 1988, and the VEBA Trust investment income were used to
pay the cost of providing medical, dental, accident, sickness,
and long-term disability benefits (and administrative costs)
under the Plan to petitioner's employees and retirees as those
benefits and costs came due during the VEBA Trust's 1988 year.
During the 1988 calendar year, only $4,092,000 was actually paid
by the VEBA Trust under the Plan for PRMB's. The VEBA Trust's
balance on November 30, 1988, was $1,525,484.
If there had been an accumulation of assets, the balance
would have reflected the reserve contributions for 1986 and 1987,
less any amounts actually paid for PRMB's during 1986 and 1987.
The 1986 deductible contribution amount (the amount actuarially
determined as necessary to create a reserve for PRMB's) was
$27,041,478. During the 1987 plan year, $2,787,000 was paid by
the VEBA Trust for PRMB's. Accordingly, the beginning balance
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