- 44 - contributions to a black lung benefit trust20 is the greater of “(i) the average remaining working life of miners who are present employees of the taxpayer, or (ii) 10 taxable years.” Sec. 192(c)(1)(B). We conclude, therefore, that the amortization rules applicable to pensions do not apply to the computation of the section 419A(c)(2) reserve. In Gen. Signal Corp. v. Commissioner, 103 T.C. at 240, in light of the taxpayer’s assertions that the phrase “reserve funded” does not have a commonly understood meaning, we assumed arguendo that the phrase was ambiguous and considered the legislative history. We shall do likewise in this case. In consulting the legislative history of section 419A, we are mindful that the relevant portion of the committee report states: Prefunding of life insurance, death benefits, or medical benefits for retirees.--The qualified asset account limits allow amounts reasonably necessary to accumulate reserves under a welfare benefit plan so that 20 Sec. 192(b) limits contributions to a black lung benefit trust as follows: SEC. 192(b). Limitation.--The maximum amount of the deduction allowed by subsection (a) for any taxpayer for any taxable year shall not exceed the greater of-- (1) the amount necessary to fund (with level funding) the remaining unfunded liability of the taxpayer for black lung claims filed (or expected to be filed) by (or with respect to) past or present employees of the taxpayer, or (2) the aggregate amount necessary to increase each trust described in section 501(c)(21) to the amount required to pay all amounts payable out of such trust for the taxable year.Page: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
Last modified: May 25, 2011