Wachtell, Lipton, Rosen & Katz, David M. Einhorn, 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 the statute “is not violated when an actuary chooses an assumption that is within the range of reasonable assumptions, even when the assumption is at the conservative end of that range”
• upholding actuarial decision to choose conservative estimates in selecting funding rates and using the same rate across 41 different plans against IRS’s charge that actuary didn’t make specific findings as to each plan’s anticipated performance
• “[T]he ‘best estimate’ requirement … is principally designed to [e]nsure that the chosen assumptions actually represent the actuary’s own judgment rather than the dictates of plan administrators or sponsors.”
• the statute “is not violated when an actuary chooses an assumption that is within the range of reasonable assumptions, even when the assumption is at the conservative end of that range, provided the chosen assumption is the actuary’s best estimate of anticipated plan experience.”

Source: CourtListener parenthetical corpus (CC0).