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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.
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