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for the plan year are no greater than the limitation. H. Rept.
93-807, at 101, 1974-3 C.B. (Supp.) at 336. Under section
413(b)(7), the anticipated employer contributions for a plan year
are to be determined in a manner consistent with the manner in
which actual employer contributions are determined.
We would repeat at this juncture that although sections
404(a)(1)(A) and 413(b)(7) establish outside limits on the amount
that may be deducted in a given taxable year, these sections do
not determine the amount of the deduction. Nevertheless, we
think sections 404(a)(1)(A) and 413(b)(7) establish the approach
to be taken to determine the amount of the actual deduction for
contributions to CBA Plans.
In a case such as this, where a number of employers are
contributing to any given plan--and here 29 different CBA Plans
with differing plan years are involved--the computation of any
contributing employer's total contribution deduction for a
taxable year is obviously a very complex operation. But it
stands to reason that the anticipated contributions from each
employer must be based upon a 12-month year, and the subsequent
contributions, and the consequent deductions, in order to be
consistent as required by section 413(b)(7) must likewise be
based upon a 12-month year. A taxpayer-employer such as
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