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set aside does not exceed the limitation prescribed by section
512(a)(3)(E)(i). See sec. 512(a)(3)(E)(i). We have held that
the plain language of section 512(a)(3)(B) treats non-member
income set aside to provide for the payment of reasonable costs
of administration directly connected with a purpose described in
section 512(a)(3)(B)(ii) as set aside for a purpose described in
that section. We further hold that “a set-aside for any purpose
specified in clause (ii) of subparagraph (B)” of section
512(a)(3) to which the limitation prescribed by section
512(a)(3)(E)(i) applies is a set-aside to provide for the payment
of life, sick, accident, or other benefits and reasonable costs
of administration directly connected with providing for the
payment of such benefits. We also hold that the limitation
prescribed by section 512(a)(3)(E)(i) applies to the amounts of
non-member income at issue that the Trust set aside to provide
for the payment of reasonable costs of administration directly
connected with providing for the payment of health care benefits.
The Trustee advances an alternative argument in the event
that the Court were to hold, as we have, that the limitation
prescribed by section 512(a)(3)(E)(i) applies to the amounts of
non-member income at issue. According to the Trustee’s alterna-
tive argument, in calculating for each year at issue the limita-
tion prescribed by section 512(a)(3)(E)(i), the plain language of
that section requires that not only the Trust’s account limit
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