Stepnowski v. Comm'r
United States Tax Court
Hercules amended its defined benefit plan in 2001. The amendment to the plan's lump-sum payment option replaced the interest rate assumption that had previously been used to calculate the present value of a participant's accrued benefit with the annual interest rate on 30-year Treasury securities. Hercules filed a request for a determination that the amended plan met all of the qualification requirements that were in effect under sec. 401(a), I.R.C.
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Hercules amended its defined benefit plan in 2001. The amendment to the plan's lump-sum payment option replaced the interest rate assumption that had previously been used to calculate the present value of a participant's accrued benefit with the annual interest rate on 30-year Treasury securities. Hercules filed a request for a determination that the amended plan met all of the qualification requirements that were in effect under sec. 401(a), I.R.C. P, as an interested party, sent a letter to the IRS regarding Hercules' determination request. P asserted that the amendment to the plan's…
1Opinion of the Court
OPINION
Cohen, Judge:
Respondent Commissioner of Internal Revenue (respondent Commissioner) issued a favorable determination letter to respondent Hercules Incorporated (Hercules) in which respondent Commissioner determined that the pension plan of Hercules Incorporated, as amended (the amended plan), met the qualification requirements of section 401(a). Charles P. Stepnowski, petitioner, filed a petition for declaratory judgment (retirement plan) pursuant to section 7476(a) challenging respondent Commissioner’s determination. Hercules was joined as party/respondent to this case by order dated…
2Cases cited16 opinions
- Remmer v. United StatesSupreme Court of the United States · 1956
- Houston Lawyer Referral Service, Inc. v. CommissionerUnited States Tax Court · 1978
- R.H. Ashenbaugh v. Crucible Inc. 1975 Salaried Retirement PlanCourt of Appeals for the Third Circuit · 1988
- Thompson v. CommissionerUnited States Tax Court · 1978
- Armco, Inc. v. CommissionerUnited States Tax Court · 1986
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3Cited by7 opinions
- Charles P. Stepnowski v. Commissioner of Internal Revenue Hercules IncorporatedCourt of Appeals for the Third Circuit · 2006
- RSW Enterprises, Inc. v. CommissionerUnited States Tax Court · 2014
- Christy & Swan Profit Sharing Plan v. Comm'rUnited States Tax Court · 2011
- Charles P. Stepnowski v. CommissionerUnited States Tax Court · 2005
- RSW Enterprises, Inc. v. CommissionerUnited States Tax Court · 2014
2 more not listed; retrieve them via the Exa API.