The consulting actuary assumed a 5% pre-retirement rate of return, used the unit credit actuarial cost method and assumed that the subject participant would retire at age 55. The Internal Revenue Service challenged the validity of the unit credit actuarial cost method and the actuarial assumptions, and in particular, the 5% interest rate in light of the fact that the plan trustee had “locked in” fixed income rates of return in excess of the actuarially assumed 5% rate. The case was the first of more than 1,500 defined benefit pension plans subjected to the Small Plan Audit Program, ultimately resolved in favor of the taxpayers and against the Internal Revenue Service. 882 F.2d 229 (7th Cir. 1989).