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set aside3 to provide for the payment of reasonable costs of
administration directly connected with providing for the payment
of health care benefits subject to the limitation prescribed by
section 512(a)(3)(E)(i)? We hold that it is.
(2) In calculating for each year at issue the limitation
prescribed by section 512(a)(3)(E)(i), is the amount of assets
that the Trust set aside to provide for the payment of health
care benefits, including reasonable costs of administration
directly connected with providing for the payment of such bene-
fits, to be reduced by the amount of the reserve described in
section 419A(c)(2)(A) for post-retirement medical benefits
(reserve for post-retirement medical benefits)? We hold that it
is not.
Background
This case was submitted fully stipulated. The facts that
have been stipulated are so found except as stated herein.
At the time of the filing of the petition, the Trust’s
address was in care of its trustee, Key Trust Company of Ohio,
N.A. (Trustee), in Cleveland, Ohio.
On December 30, 1987, The Sherwin-Williams Company (Sherwin-
Williams) established the Trust to fund health care benefits for
participants in The Sherwin-Williams health care plan (Sherwin-
3All references herein to an amount set aside are to an
amount set aside within the meaning of sec. 512(a)(3)(B).
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