- 7 - On the basis of respondent's determination that Rozenblatt and Jakubowicz were entitled to receive only reduced joint and 100-percent survivor annuities and after several other adjustments not relevant herein, respondent disallowed as excess contributions for 1987, 1988, and 1989, respectively, $177,505, $177,760, and $175,454 of the total claimed deductions relating to the plans. Also, for 1988, 1989, and 1990, respondent determined that petitioner was liable for excise taxes under section 4972 with regard to the portion of petitioner’s contributions to the plans that, in respondent's view, constituted excess contributions. Discussion Generally, employers may deduct contributions to qualified pension plans that fund retirement benefits for plan participants. Sec. 404(a)(1)(A). Such contributions, however, for Federal income tax purposes, are deductible by employers only to the extent contributions to the plans do not exceed the actuarially projected costs of funding benefits provided under the plans. Sec. 1.404(a)-3(b), Income Tax Regs. Section 1.404(a)-3(b), Income Tax Regs., provides: "In no event shall costs for the purpose of section 404(a)(1) exceed costs based on assumptions and methods which are reasonable in view of the provisions and coverage of the plan".Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011