EXHIBIT 5.1
INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY
P. 0. BOX 2508
CINCINNATI, OH 45201
Employer Identification Number:
Date: 34-1899137
DLN:
GOODYEAR DUNLOP TIRES NORTH 17007127026031
AMERICA LTD Person to Contact:
C/O MARK E BRAND LARRY GREEN ID# 52007
PHILLIPS LYTLE ET AL Contact Telephone Number:
3400 HSBC CENTER (877) 829-5500
BUFFALO, NY 14203-0000 Plan Name:
GOODYEAR DUNLOP TIRES N AMERICA
LTD 401K RETIREMENT SAVINGS PLAN
Plan Number: 009
Dear Applicant:
We have made a favorable determination on the plan identified above
based on the information you have supplied. Please keep this letter, the
application forms submitted to request this letter and all correspondence with
the Internal Revenue Service regarding your application for a determination
letter in your permanent records. You must retain this information to preserve
your reliance on this letter.
Continued qualification of the plan under its present form will depend
on its effect in operation. See section 1.401-1(b)(3) of the Income Tax
Regulations. We will review the status of the plan in operation periodically.
The enclosed Publication 794 explains the significance and the scope of
this favorable determination letter based on the determination requests
selected on your application forms. Publication 794 describes the information
that must be retained to have reliance on this favorable determination letter.
The publication also provide examples of the effect of a plan's operation on
its qualified status and discusses the reporting requirements for qualified
plans. Please read Publication 794.
This letter relates only to the status of your plan under the Internal
Revenue Code. It is not a determination regarding the effect of other federal
or local statutes.
This determination letter is applicable for the amendment(s) executed on
3/23/99 & 8/25/99.
This determination letter is also applicable for the amendment(s} dated
on 7/28/00 & 3/1/01.
This letter considers the changes in qualification requirements made by
the Uruguay Round Agreements Act, Pub. L. 103-465, the Small Business Job
Protection Act of 1996, Pub. L. 104-188, the Uniformed Services Employment and
Reemployment Rights Act of 1994, Pub. L. 103-353, the Taxpayer Relief Act of
1997, Pub. L. 105-34, the Internal Revenue Service Restructuring and Reform Act
of 1998, Pub. L. 105-206, and the Community Renewal Tax Relief Act of 2000,
Letter 835 (DO/CG)
-2-
GOODYEAR DUNLOP TIRES NORTH
Pub. L. 106-554.
The requirement for employee benefits plans to file summary plan
descriptions (SPD) with the U.S. Department of Labor was eliminated effective
August 5, 1997. For more details, call 1-800-998-7542 for a free copy of the SPD
card.
The information on the enclosed addendum is an integral part of this
determination. Please be sure to read and keep it with this letter.
We have sent a copy of this letter to your representative as indicated
in the power of attorney.
If you have questions concerning this matter, please contact the person
whose name and telephone number are shown above.
Sincerely yours,
/s/ Paul T. Shultz
Paul T. Shultz
Director,
Employee Plans Rulings & Agreements
Enclosures:
Publication 794
Addendum
Letter 835 (DO/CG)
-3-
GOODYEAR DUNLOP TIRES NORTH
This determination letter includes the amendment(s) adopted on 4/24/01.
Letter 835 (DO/CG)