"Plan A provides that a covered employee will be eligible to receive medical benefits upon attainment of a specified age, which Plan A refers to as the employee's 'retirement age'. These medical benefits are available upon attainment of that age without regard to severance from employment with Company X.... The section 419A(c)(2) addition to a reserve for post-retirement medical benefits does not include amounts for benefits expected to be provided with respect to an employee prior to the employee's severance from employment with the employer maintaining the plan. Moreover, the addition to the reserve does not include amounts funded more rapidly than on a level basis over the covered employees' working lives. Thus, Company X's contributions to the welfare benefit fund are not deductible under section 419A(c)(2) to the extent they include such amounts."  MORE >>