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sec. 57.06, at 654 (Sands 4th ed. 1984))). Thus, it is the
reserve, not merely a contribution equal to the normal cost for the
year, that must be computed in determining the account limit.
Respondent asserts that courts have held in prior cases, such
as Gen. Signal Corp. v. Commissioner, supra, Square D Co. v.
Commissioner, supra, and Parker-Hannifin Corp. v. Commissioner,
supra, that “reserve” as used in section 419A(c)(2) does not mean
a measure of liability. At issue in those cases, however, was
whether section 419A(c)(2) required the actual funding of a
reserve. The taxpayers in those cases argued that term “reserve”
was an actuarial term of art meaning “a quantity of liability” that
did not require actual funding. We held that a mere quantity of
liability does not constitute a “reserve funded over the working
lives of the covered employees”; i.e., we held that section
419A(c)(2) requires the actual funding of the reserve.
When Congress uses a term of art that has an established
meaning, a strong presumption arises that Congress intends to
incorporate that meaning. Morissette v. United States, 342 U.S.
246, 263 (1952). Congress’s choice of the word “reserve” (rather
than “account” or “fund”, for example) connotes a measure of
liability. W. Natl. Mut. Ins. Co. v. Commissioner, 102 T.C. 338,
373 (1994) (“reserves * * * are estimates of liabilities: ‘“best
estimates” of future settlement costs’” (quoting Salzmann,
Estimated Liabilities For Losses & Loss Adjustment Expenses 155
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