Rev. Rul. 69-493

A labor union established a pension plan for the benefit of the employees of the union. The plan was not adopted by any other employer. Several of the participants in the plan were not employees of the union.

Held, the pension plan in this case does not meet the qualification requirements of section 401(a) of the Internal Revenue Code of 1954 since it covers persons who are not employees of the union. See section 1.401-1(a)(3)(ii) of the Income Tax Regulations which provides that for a trust to be qualified under section 401(a) of the Code it must be part of a pension, profit-sharing, or stock bonus plan established by an employer for the exclusive benefit of his employees or their beneficiaries.