IRS guidance on treatment of employer funds used to buy out plan's annuity contract surrender charges

[Guest jusducki]

Can someone refer me to what was either an IRS Notice or PLR that discusses when an employer buys out surrender charges on annuities when a transfer of assets is made, that the IRS considers the buyout an employer contribution not only for testing purposes but also for deductibility? I know this is vague but hopefully someone here has a far better memory than I in locating this. Thank you.

[david rigby]

http://benefitslink.com/IRS/revrul2002-45.shtml

[KJohnson]

http://www.benefitslink.com/boards/index.p...9&hl=cdsc&st=15