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both plans as of that date of at least $707,451. On brief,
respondent states that the deficiencies were determined using the
$353,762 figure under the Pension Plan. We accept $353,762 as
Gant's Pension Plan vested accrued benefit as of June 30, 1991,
since neither party has urged a different amount, the "at least"
modifier in the stipulation notwithstanding.
There is no indication in the record, and we have no reason
to believe, that Gant's vested accrued benefit under the Pension
Plan as of June 30, 1991, and his account balance under the
Profit Sharing Plan as of that date, have been taxed prior to
petitioners' 1991 taxable year. Petitioners do not challenge
respondent's computation of the 1992 and 1993 accruals. We
accordingly hold that petitioners must include in 1991 gross
income Gant's $707,451 total vested accrued benefits under the
Pension Plan and Profit Sharing Plan as of June 30, 1991, and
must include in gross income the additional accrued benefits
under both plans in 1992 and 1993, respectively, as determined by
respondent.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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