Other 200641006: IRS closes withdrawn pension funding extension request

Number
200641006
Outcome
Other outcome
Document type
Determination Letter
IRS subject
Minimum Funding Standards
Code sections
§ 412
Ruling dated
July 20, 2006
Publicly released
October 13, 2006

Apply this to your situation

This page covers one taxpayer's determination, issued in 2006, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2006
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
Transcribed from a scanned original: the IRS released this determination as an image-only PDF. The full text below is a machine transcription, proofread against the scan. Check the original PDF before quoting exact language.
View official IRS release (PDF)

Plain-English summary

A pension plan had asked for more time to amortize its unfunded liabilities under section 412(b)(2)(B). Its authorized representative later asked the IRS to withdraw that request. The IRS confirmed the withdrawal and closed the case. This letter makes no determination on whether the plan would have qualified for an extension.

Ruling snapshot

  • Question: What happened to the plan's request to extend amortization of unfunded liabilities?
  • Outcome: Other; the request was withdrawn and the case closed.
  • Key authorities: IRC § 412(b)(2)(B); ERISA § 302(b)(2)(B).

Full text (IRS public release)

Significant Index No. 0412.00-00

200641006

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224

TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION

JUL 20 2006

In re:

EIN:

This letter constitutes notice that pursuant to your authorized representative's request in a letter dated July 13, 2006, your request for an extension for amortizing the unfunded liabilities described in section 412(b)(2)(B) of the Internal Revenue Code and section 302(b)(2)(B) of the Employee Retirement Income Security Act of 1974 for the plan year beginning April 1 has been withdrawn. Accordingly, the case has been closed by this office.

We have sent a copy of this letter to the Manager, EP Classification in , to the Manager, EP Compliance Unit in and to your authorized representatives pursuant to a power of attorney on file in this office.

If you require further assistance in this matter, please contact

Sincerely yours,

Donna M. Prestia, Manager
Employee Plans Actuarial Group 2

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