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September of 1965 until he retired in July of 1988. Montana
State University participates in the Montana Teachers Retirement
System of the State of Montana (MTRS), a qualified defined
benefit pension plan under section 401(a).
During his employment, petitioner made mandatory after-tax
contributions to the MTRS. From July of 1985 to July of 1988,
petitioner made after-tax contributions in accordance with
Montana State law allowing for additional contributions to build
up a retirement base. Petitioner’s contributions to the MTRS
were as follows:
Year Taxed Contribution
1965-66 $350
1966-67 350
1967-68 611
1968-69 639
1969-70 793
1970-71 822
1971-72 922
1972-73 887
1973-74 1,131
1974-75 1,122
1975-76 1,613
1976-77 1,592
1977-78 1,814
1978-79 1,102
1979-80 1,774
1980-81 529
1981-82 1,838
1982-83 1,012
1983-84 2,893
1984-85 7,042
1987-88 7,898
Total 36,734
Petitioner’s nominal basis in his pension plan is $36,734. Since
petitioner’s retirement in July of 1988, he has been receiving a
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