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American Academy of Actuaries Expresses Concern to IRS About 'Good Faith Compliance' Standard (PDF)
American Academy of Actuaries Link to more items from this source
July 11, 2003

Excerpt: Many of our clients are companies that are finding it more and more difficult to continue sponsoring defined benefit pension plans. We realize that we must help them operate their plans with a reasonable degree of operational comfort. At present, we find ourselves unable to do so without fearing subsequent financial sanctions by the Service many years later.

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