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Section 404(a)(6) expands somewhat the time of payment
provision at the beginning of section 404(a)(1)(A) by providing:
(6) Time when contributions deemed made.--For purposes
of paragraphs (1), (2), and (3), a taxpayer shall be deemed
to have made a payment on the last day of the preceding
taxable year if the payment is on account of such taxable
year and is made not later than the time prescribed by law
for filing the return for such taxable year (including
extensions thereof).
As a further refinement of the section 404(a) limitations on
the deductibility of contributions, section 413 provides certain
rules that apply exclusively to "collectively bargained plans,
etc." Section 413(a) provides that subsection (b) applies to any
plan (and any trust thereunder) maintained pursuant to a CBA;
i.e., a CBA Plan. Various paragraphs of subsection (b) provide
rules that relate to CBA Plans, but the relevant paragraph for
our present purposes is paragraph (7), which furnishes a road map
for applying section 404(a) limitations insofar as they relate to
CBA Plans. Section 413(b)(7) provides:
(7) Deduction limitations.--Each applicable limitation
provided by section 404(a) shall be determined as if all
participants in the plan were employed by a single employer.
The amounts contributed to or under the plan by each
employer who is a party to the agreement, for the portion of
his taxable year which is included within such a plan year,
shall be considered not to exceed such a limitation if the
anticipated employer contributions for such plan year
(determined in a manner consistent with the manner in which
actual employer contributions for such plan year are
determined) do not exceed such limitation. If such
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