§1112

It provides that "[h]ighly compensated employees * * * are taxable on the value oftheir vested accrued benefit attributable to employer contributions and income on any contributions to the extent such amounts have not previously been taxed to the employee." Id.

section 348(d), which provides : (d) A claim against the estate or the debtor that arises after the order for relief but before conversion in a case that is converted under section 1112, 1208, or 1307 of this title * * * shall be treated for all purposes as if such claim had arisen immediately before .

Hurley appéaled that decision to the U.S. District Court for the Eastern District of Pennsylvania, -but in June 1995, ·she withdrew her, appeal. . - 20 - respect to the validity of. the $50,000 legacy to Ms. Hurley, finding that the legacy was induced by.fraud.'. On April 17, 1996, the administrators pro ·tem. and Ms. Hurley en

1112(a) and (e), 100 Stat. 2440, 2445, effective for plan years beginning after Dec. 31, 1988. 5 Sec. 410(b)(1)(B), as in effect before the enactment of the TRA amendments in 1986, provided that a plan can alternatively meet the coverage requirements by benefiting such employees as qualify under a classification set up by the employer and foun