Rev. Rul. 54-152

An employees' pension trust under which the employer does not contribute to the trust fund (the trust fund consisting only of stated contributions of employees and the income thereon), but does obligate itself to pay the full amount of the stipulated retirement benefits to each retired employee participant after the funds in the trust to the employee's credit have been exhausted, will not fail to qualify for exemption from Federal income tax under section 165 of the Internal Revenue Code by reason of such limitations upon contributions. Retirement benefits paid by the employer to retired employees pursuant to its obligation under such a plan may be deducted from gross income in accordance with section 23(p)(1)(D) of the Code. See section 39.23(p)-11, Regulations 118.