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employers are subject to subpart D. Under section 419, each
employer's deduction for its contribution to its separate plan is
limited to the plan's "qualified cost" for the year, less the
plan's after-tax income. Sec. 419(a), (b), and (c); see also
National Presto Indus., Inc. v. Commissioner, 104 T.C. 559,
566-567 (1995). An employer's qualified cost equals the
qualified direct cost for the taxable year, plus an addition to a
qualified asset account. Sec. 419(c)(1).
Respondent has proffered to the Court calculations of each
corporation's qualified cost and allowable deduction with respect
to its plan. These calculations show that Young & Young is
entitled to deduct $11 for 1989, and that no other corporation is
allowed a deduction with respect to its plan. Petitioners do not
dispute the mechanics of respondent's calculations, and
petitioners have not supplied the Court with alternative
calculations of qualified cost. Petitioners' position, which we
have rejected, is that the corporations can deduct their
contributions in full.
We have reviewed respondent's calculations, and we are
satisfied that they are correct. Accordingly, we sustain
respondent's determination that the corporations are not allowed
any deduction for the subject years with respect to their
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