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certificate signed by the general secretary of the Union
Nationale des Mutuelles Retraite des Instituteurs et des
Fonctionnaires de l’Education Nationale et de la Fonction
Publique (MRF) on February 28, 2002. That document states that
petitioner was saving through an intermediary of MRF’s known as
Caisses Autonomes, a soldier’s benefit society annuity with the
participation (not further described in the record) of France.
It also states that contributions are deductible if the pension
does not exceed the maximum current threshold, which was the
equivalent of 01372.72 (euros) in 2001.
The second document is an undated letter to petitioner from
Union Mutualistic Retraite (UMR) responding to her request dated
July 11, 2003, to change her contributions.
The third document appears to (1) be excerpts from an
article by the Direction des Retraites CDC (not otherwise
described in the record), about (a) French parliamentary debates
on French pensions and retirement system and (b) new retirement
products that are the result of an ordinance dated April 19,
2001; and (2) a summary or explanation of some of the features of
a French pension plan offered by UMR.
Petitioner contends that these documents show that the
French pension plan generally corresponds to a trust under
section 501(c)(18). We disagree. First, there is no evidence
(1) that petitioner paid the $1,916 to a trust or anything
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