Vinson & Elkins, J. Evans Attwell, Tax Matters Partner v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that a goal of the best-estimate test is to ensure that the “assumptions truly came from the plan actuary” and were not “chosen by plan management for tax planning or cash flow purposes”
• explaining the determination of which mortality table was to be used in determining pre-retirement death benefits versus post-retirement annuities
• explaining the determination of which mortality table was to be used in determining pre-retirement death benefits versus post-retirement annuities
• “The statute refers to the actuary’s best estimate, not that of a court or of outside experts.”
• “Congress intended to give actuaries some leeway and freedom from second- guessing.”
• interpreting identical language in 26 U.S.C. § 412(c)(3)

Source: CourtListener parenthetical corpus (CC0).