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impermissible broadening of the statute. Petitioner changed the
tax year of the VEBA Trust from a calendar yearend to a fiscal
year ending November 30 during November of 1985. Changing the
yearend of the VEBA Trust was an attempt to avoid the limit on
additions to a qualified asset account as imposed by section
419A. By making a full contribution during December for the next
year's claims, petitioner sought to take a deduction for the year
of the contribution while treating the contribution as being made
in the following year of the VEBA Trust and avoiding the account
limit imposed by sections 419 and 419A. Petitioner argues that,
but for the regulation, its intrayearend contribution, made
during December 1986, would be deductible in 1986, because that
contribution would not be required to be included as part of the
VEBA as of its taxable year ending November 30, 1986.
Accordingly, petitioner argues, the regulation contradicts the
plain language of section 419 and is invalid. Petitioner
contends that it is therefore entitled to a deduction for the
1986 contribution without application of the limitation.
2. Review of the Regulation
In General Signal Corp. & Subs. v. Commissioner, supra,
where the facts were virtually identical to the facts in this
case, the taxpayer did not argue that section 1.419-1T, Q&A-
5(b)(1), Temporary Income Tax Regs., supra, was invalid, so we
left that question for another day. Id. at 238. Accordingly, we
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