Susan Jane Hoyez, C.P.A. - Page 3




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          for excise tax under section 4971(a) and imposed a failure to               
          file penalty under section 6651(a)(1).                                      
                                     Discussion                                       
          A. Excise Tax Under Section 4971(a)                                         
               Section 412 was designed to ensure that qualified plans                
          would accumulate sufficient assets to meet those plans’                     
          obligations to their beneficiaries.  See H. Rept. 93-779, at 73             
          (1974), 1974-3 C.B. 244, 316.  Section 412(a), in part, provides:           
               A plan to which this section applies shall have satisfied              
               the minimum funding standard for such plan for a plan year             
               if as of the end of such plan year, the plan does not have             
               an accumulated funding deficiency. For purposes of this                
               section and section 4971, the term “accumulated funding                
               deficiency” means for any plan the excess of the total                 
               charges to the funding standard account for all plan years             
               (beginning with the first plan year to which this section              
               applies) over the total credits to such account for such               
               years or, if less, the excess of the total charges to the              
               alternative minimum funding standard account for such plan             
               years over the total credits to such account for such years.           
               * * *                                                                  
               To ensure that a qualified plan maintains minimum funding,             
          section 412(b)(1) requires employers to maintain a “funding                 
          standard account” for each plan.  Charges to the account consist            
          of the normal cost of the plan for the plan year and the                    
          amortization of certain costs and liabilities.  See sec.                    
          412(b)(2).  Credits to the account consist, generally, of                   
          employer contributions for the plan year and the amortization of            
          certain adjustments.  See sec. 412(b)(3).                                   








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