What is the dollar limit if taxes have been paid on prior DB Plan

[Guest Roman]

One-man Corporation had a DB plan terminated a few years back in which the benefit had been distributed and the employer-owner paid taxes on. Now, he wants to start a new DB. Since he has already paid taxes on the previous DB, can the dollar limit be restarted (instead of being offset by the accrued benefit of the prior DB) as if the previous DB had never existed? Do you have a citation on your answer? Thanks.

[mwyatt]

Look at IRC 415(f). Specifically,

(f)(1) IN GENERAL: For purposes of applying the limitations of subsections (B), ©, and (e) --

(A) all defined benefit plans (whether or not terminated) of an employer are to be treated as one defined benefit plan...

I don't think it gets any clearer than that, so yes, you need to offset the new limit by the benefit already received (although you should find a sufficient benefit remaining to be funded especially after EGTRRA limits kick in).