Caterpillar Tractor Co. v. Commissioner

72 T.C. 1088, 1979 U.S. Tax Ct. LEXIS 60, 1 Employee Benefits Cas. (BNA) 1830
CourtUnited States Tax Court
DecidedSeptember 13, 1979
DocketDocket No. 13616-78R
StatusPublished
Cited by8 cases

This text of 72 T.C. 1088 (Caterpillar Tractor Co. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Caterpillar Tractor Co. v. Commissioner, 72 T.C. 1088, 1979 U.S. Tax Ct. LEXIS 60, 1 Employee Benefits Cas. (BNA) 1830 (tax 1979).

Opinion

OPINION

Tannenwald, Judge:

Petitioner seeks a declaratory judgment pursuant to section 74761 that its noncontributory pension plan, as amended December 17, 1976, qualifies under section 401(a).

The case was submitted under Rule 122, Tax Court Rules of Practice and Procedure, on the basis of the pleadings and the facts set forth in the administrative record.

Petitioner is a corporation with its principal office in Peoria, Ill., at the time of filing the petition herein. At all pertinent times, its business has included the manufacture and sale of earth moving and industrial equipment.

Some time prior to 1976, petitioner adopted a retirement plan known as the Caterpillar Tractor Co. Non-Contributory Pension Plan (the plan). Prior to the enactment of the Employees Retirement Income Security Act (hereinafter ERISA), the plan, as originally adopted and as amended November 21, 1973, was determined by respondent to meet the requirements of section 401(a), I.R.C. 1954.

On December 17, 1976, petitioner entered into an agreement with the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, and certain of its affiliated local unions, amending the plan as of October-1, 1976. The plan (as so amended) included provisions which had the following effect:

(a) “Normal Retirement Age” was defined as age 65.

(b) Mandatory retirement was set at age 66.

(c) The “normal retirement benefit” of a participant was defined as that amount payable to him under the specified formula, if he possessed at least 10 years of credited service upon retirement.

As a result of the foregoing provisions, employees with less than 10 years of credited service at the time they reach mandatory retirement age (age 66) are not entitled and can never become entitled to receive any retirement benefits under the plan. A new employee who is past his 56th birthday at the time first employed can never enjoy any retirement benefits.

By letters dated March 8, 1977, and August 1,1977, petitioner requested a determination that the plan met the requirements of section 401(a), and that the trusts administering such plans were exempt under the provisions of section 501(a). Under date of November 1, 1977, the Office of the District Director at St. Louis, Mo., advised petitioner by letter that, on the basis of the information supplied, that office had made a favorable determination with respect to such application.

In February of 1978, the foregoing Office of the District Director received a communication from the Department of Labor and copies of correspondence with respect to the status under the plan of certain employees or former employees of petitioner and one employee in particular. As a result of this communication, that office sought technical advice from the national office of the Internal Revenue Service as to whether the plan met the requirements of sections 410 and 411.

A letter of technical advice was issued in response to such request, concluding that the plan failed to meet the requirements of section 411(a). Petitioner was advised by the Office of the District Director, St. Louis, Mo., that unless it retroactively amended the plan so as to delete the requirement of 10 years of credited service at mandatory retirement age, a final adverse determination letter would be issued. Petitioner declined to so amend the plan.

A “Final Adverse Determination Letter” was issued to petitioner on or about October 27, 1978, reading, insofar as pertinent herein, as follows:

This is a FINAL ADVERSE DETERMINATION LETTER indicating our conclusion that the plan identified above does not meet the requirements of section 401 of the Internal Revenue Code for plan years beginning on or after October 1, 1976. This adverse determination is being made pursuant to technical advice of the National Office of the Internal Revenue Service and supercedes [sic] our determination letter dated November 1,1977. * * *

The primary dispute between the parties focuses on the proper interpretation to be accorded section 411(a),2 the requirements of which must be met in order for the plan to qualify under section 401(a) (see par. (7) thereof). Involved in the question of interpretation is the impact of sections 401(a)(14) (relating to payment of benefits)3 and 410(a)(2) (relating to participation requirements).4

The parties are in agreement that, with one exception, the plan satisfies the minimum vesting standards of section 411 and, therefore, the requirements of section 401(a)(7). That exception relates to the meaning to be accorded the clause in the first sentence of section 411(a) that, in order to qualify, the plan of which the trust is a part must provide “that an employee’s right to his normal retirement benefit is nonforfeitable upon the attainment of normal retirement age (as defined in paragraph (8)).” See n. 2 supra. The factual predicate of the dispute over the applicability of this language is that, since there is no maximum age for hiring specified in the plan, an employee who is over 56 when he is hired will not have satisfied the 10-year service requirement by the time he reaches the mandatory retirement age of 66 and therefore will not be entitled to any benefits under the plan.5

Petitioner contends that the plan meets the requirements of the above-quoted clause in section 411(a), because the plan does not involve any forfeiture of a “normal retirement benefit.” Petitioner argues that the plan simply provides that such benefit for a participant having less than 10 years of service is zero and that such a provision is permitted under section 411(a). Petitioner supports its argument with a semantical analysis of the various provisions involved and charges that respondent’s position that petitioner’s contention makes a mockery of the above-quoted clause is based upon a confusion in his understanding of the terms “accrual,” “vesting,” and “participation.” For the reasons hereinafter set forth, we reject petitioner’s contentions and agree with the respondent that the plan does not meet the vesting standards of section 411(a).

We see no need to delve deeply into the tortuous history of the legislative path of ERISA from the time of its initial consideration by the Congress to its final enactment. We think, however, that two elements of that history are worthy of note. The first is that neither the House nor the Senate versions, as passed by those legislative bodies respectively, contained the above-quoted clause in their counterpart of section 411(a); each version simply set forth the specific conditions, albeit with variations, which found their way into section 411(a) in its final form. See H.R. 2, 93d Cong., 2d Sess. sec. 1012, as passed by the House of Representatives on February 28,1974, and section 221, as passed by the Senate on March 4, 1974.

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Caterpillar Tractor Co. v. Commissioner
72 T.C. 1088 (U.S. Tax Court, 1979)

Cite This Page — Counsel Stack

Bluebook (online)
72 T.C. 1088, 1979 U.S. Tax Ct. LEXIS 60, 1 Employee Benefits Cas. (BNA) 1830, Counsel Stack Legal Research, https://law.counselstack.com/opinion/caterpillar-tractor-co-v-commissioner-tax-1979.