Internal Revenue Service
Revenue Ruling
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smRev. Rul. 64-84
1964-1 C.B. 164
Full Text
Rev. Rul. 64-84
Revenue Ruling 63-11, C.B. 1963-1, 94, dealing with asset valuation for computing costs of a pension plan for use in determining limitations on deductions for contributions to the pension plan, states in part, as follows:
Further, an employer's contribution to a pension trust fund would not be deductible to the extent that the assets of the plan valued on an acceptable basis already exceed the employer's accrued liability . (Emphasis added.)
The expression `employer's accrued liability,' as used in the Revenue Ruling, refers to the accrued liability computed according to the valuation method and assumptions used in determining acceptable limitations under section 404(a)(1) of the Internal Revenue Code of 1954.
Revenue Ruling 63-11 is hereby clarified.