MPPAAMultiemployer Pension Plan Amendments Act of 1980
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Further, many courts in MPPAA cases have accepted the Supreme Court's analysis in Groetzinger in distinguishing trades or businesses from investments.
Consequently, when the MPPAA was enacted, it required an employer withdrawing from a multiemployer pension plan to pay an amount equal to the employer's proportionate share of the plan's unfunded vested benefits.
414(c), the courts in the MPPAA cases generally have held that the term should be interpreted in light of the intentions of the Employee Retirement Income Security Act of 1974; see, e.