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pension plans, (5) the law in effect before the enactment of
section 419, and (6) principles of actuarial practice. Respondent
contends that the cost of the postretirement benefit must be spread
over the remaining working lives of the covered employees.
Respondent further contends that, since retirees have no remaining
working lives, the cost must spread over the remaining working
lives of the active employees. Respondent concludes, therefore,
that the aggregate cost method is the proper method for computing
the account limit for the reserve under section 419A(c)(2).
Respondent asserts in the alternative that, if the entry age normal
cost method is a proper method, then the accrued liability must be
amortized over the remaining lives of the active employees.
4. Statutory Construction
“Our first step in interpreting a statute is to determine
whether the language at issue has a plain and unambiguous meaning
with regard to the particular dispute in the case.” Robinson v.
Shell Oil Co., 519 U.S. 337, 340 (1997). We look to the
legislative history primarily to learn the purpose of the statute
and to resolve any ambiguity in the words contained in the text.
Landgraf v. USI Film Prods., 511 U.S. 244 (1994); Commissioner v.
Soliman, 506 U.S. 168, 174 (1993); Consumer Prod. Safety Commn. v.
GTE Sylvania, Inc., 447 U.S. 102, 108 (1980); United States v. Am.
Trucking Associations, Inc., 310 U.S. 534, 543-544 (1940); Allen v.
Commissioner, 118 T.C. 1, 7 (2002); Venture Funding, Ltd. v.
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