- 4 -
Addition to Tax
Year Deficiency Sec. 6662(a)
1990 $52,073,344 $5,161,509
1991 216,338,093 23,353,180
1992 417,310,889 1,047,868
1993 86,406,356 5,655,276
1994 62,493,719 5,135,972
Numerous issues have been raised as a consequence of respondent’s
determinations; many of these issues heretofore have been resolved.
The issue to be decided herein concerns the amounts petitioners may
deduct for years 1991-94 for contributions made to a voluntary
employee benefit association (VEBA) trust to provide postretirement
medical benefits to covered employees and their eligible
dependents. To determine the allowable amounts, we first must
decide the proper method to be used in computing the reserve under
section 419A(c)(2).2 Then we must decide whether petitioners used
reasonable investment rates in their actuarial computations.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly. The stipulations of facts and the attached exhibits
are incorporated herein by this reference.
2 All section references are to the Internal Revenue Code
as in effect for the years in issue.
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Last modified: May 25, 2011