Filing for a 2007 & 2008 DB plan funding waiver

[Guest GaryGaryGary]

2007 was and 2008 will be bad financial years for my client. They are filing a 2007 funding waiver for the 3 out of 4 quarterly contributions they did not make and since the envelope still has room, we're including a 2008 application as well (we know it's premature).

Question:

In the 5 year projection of the company financials, Rev. Proc. 2004-15 asks not only for a projection of the minimum required contributions but also for a projection of income and expenses. Should I read "expenses" as "GAAP expense"?

Since we made changes to the OPEB and Pension Plan, the client is in a OPEB and Pension "Income" position, as opposed to annual expense accruals.

Yes, this will be pointed out in the cover letter but it seems self defeating, especially if the reviewer don't follow what has occurred.

Thanks all.