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deduction limitation of section 404(a)(1)(A) for a given plan
year since: (1) They cannot know the exact amount of their
required contributions for a plan year until the units of service
are actually completed by their employees; (2) their tax years do
not necessarily correspond with one another; and (3) employer
contributors are not required to report to plan administrators
the deductions they claim for contributions. Section 413(b)(7)
states that all employers' contributions for a plan year will not
exceed the overall limit imposed by section 404(a)(1)(A) if the
total anticipated contributions for the plan year do not exceed
such limit. Anticipated contributions for a plan year must be
determined in a manner consistent with that in which actual
contributions are determined. Sec. 413(b)(7). Actual
contributions are calculated by plan administrators based on
units of service worked within the 12-month plan year.
Petitioner presumes that, once the total anticipated
contributions are found not to exceed the overall deductible
limit, it can thereafter elect to augment the amount of its
actual contributions for its tax year pursuant to section
404(a)(6) to take advantage of any leftover overall limitation
for the corresponding plan year (the difference between full
funding under section 412 and all anticipated employer
contributions for that plan year). Any other approach,
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