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June 1990, the Internal Revenue Service issued a favorable
determination letter to Charles Schwab for the prototype
standardized money purchase pension plan adopted by petitioner.
In December 1994, petitioner adopted a further updated version of
the Wenger plan, again using a prototype money purchase plan
offered by Charles Schwab.
The Wenger plan was in effect for petitioner’s 1994 tax
year. Petitioner is the employer who sponsors the Wenger plan
and is responsible for funding it. The Wenger plan is a
qualified plan subject to the minimum funding standards of
section 412.
The Wenger plan has a plan year ending December 31, and the
plan reports on a calendar year basis. On July 6, 1995,
petitioner filed a Form 5558, Application for Extension of Time
to File Certain Employee Plan Returns, requesting a 2-1/2-month
extension to file the annual return, Form 5500-C/R, for the
Wenger plan. The extension was granted, and the Form 5500-C/R
for the Wenger plan was therefore due on October 16, 1995.
Petitioner filed Form 5500-C/R for the Wenger plan no later than
October 16, 1995.
On Form 5500-C/R, petitioner reported that, pursuant to
section 412, the required contribution to the Wenger plan was
$18,275. Petitioner made the required contribution on October
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