Department of Finance

 

Date of this Version

1993

Document Type

Article

Citation

Journal of Actuarial Practice 1 (1993), pp. 119-132

Comments

Copyright 1993 Absalom Press

Abstract

One of the most important issues of recent years from the perspective of many pension actuaries is the IRS's small plan audit program. The program initially was expected to raise two-thirds of a billion dollars by targeting well-funded defined benefit plans with five or fewer participants. The focus of the audit was the assumed interest rate and the normal retirement age, both of which the IRS generally regarded as too low. While the focus of the audit was relatively narrow, the issue it raised was a funda mental one. The basic question was the extent to which the IRS could impose its unilateral interpretation of actuarial principles on pension actuaries. Not surprising, many small plan audit cases ended in the tax courts. In due course decisions and opinions have been rendered in three lead cases. This article presents the opinions of these cases as they relate to actuarial practice and discusses some of their implications.

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