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In the case of a defined benefit plan, the term “accrued
benefit” means the employee’s accrued benefit determined under
the plan and expressed in the form of an annual benefit
commencing at normal retirement age. Sec. 411(a)(7)(A)(i); see
also sec. 1.411(a)-7(a)(1), Income Tax Regs. More generally, an
accrued benefit represents the progressively increasing interest
in a retirement benefit that an employee earns each year, under a
formula that is provided in the plan. Bd. of Trs. of the Sheet
Metal Workers’ Natl. Pension Fund v. Commissioner, 117 T.C. 220,
228 (2001), affd. 318 F.3d 599 (4th Cir. 2003); see also
Ashenbaugh v. Crucible Inc., 1975 Salaried Ret. Plan, 854 F.2d
1516, 1524 (3d Cir. 1988).
Under section 401(a)(11), a trust forming part of a defined
benefit plan will not constitute a qualified trust unless, inter
alia, the accrued benefit payable to a vested participant is
provided in the form of a qualified joint and survivor annuity
(QJSA). See sec. 401(a)(11)(A) and (B). Section 417 provides
special rules and definitions for purposes of applying section
401(a)(11). Sec. 401(a)(11)(F).
Section 417(e) provides rules for “cash-outs” (i.e., lump-
sum payments) of a participant’s QJSA. If the present value of a
participant’s QJSA exceeds the amount that can be distributed
without the participant’s consent under section 411(a)(11),
section 417(e)(2) provides that the participant and the
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