Lucky Stores, Inc. and Subsidiaries - Page 22

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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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