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tax return, it may be possible to realize a one-time tax savings
[sic] to the extent of the tax benefit on nine months of
contributions to the plan". (Obviously, the bunching technique
could not be applied in any subsequent year because to do so
would require double counting of a bunched contributions.) For
the reasons already articulated, we do not believe the limitation
of section 413(b)(7) permits the accelerated deduction of the
"[eight or] nine months of contributions" sought by petitioner in
this case.
For the above reasons,
An Order will be issued
denying petitioner's Motion
and the Judicial Notice Motions.
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Last modified: May 25, 2011