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in the amount of $18,275 and that petitioner’s failure to make a
timely contribution would result in an accumulated funding
deficiency in such amount. The only issue is whether petitioner
made a timely contribution for the year.
Section 412(b)(3)(A) provides in pertinent part that “the
funding standard account shall be credited with * * * the amount
considered contributed by the employer to or under the plan for
the plan year”. (Emphasis added.) As applicable to a money
purchase plan, section 412(c)(10)(B) provides:
any contributions for a plan year made by an employer
after the last day of such plan year, but not later
than two and one-half months after such day, shall be
deemed to have been made on such last day. For
purposes of this subparagraph, such two and one-half
month period may be extended for not more than six
months under regulations prescribed by the Secretary.
Section 11.412(c)-12(b), Temporary Income Tax Regs., 41 Fed.
Reg. 46597 (Oct. 22, 1976), automatically extends the 2-1/2-month
period by another 6 months for a total of 8-1/2 months. Thus, an
employer’s contributions are credited to the plan’s funding
standard account for a particular plan year if the contributions
are “made” within 8-1/2 months after the last day of the plan
year. If, in the absence of a waiver, see supra note 2, the
employer makes a contribution beyond the 8-1/2-month period, the
contribution is untimely, thus resulting in an accumulated
funding deficiency. In petitioner’s case, the 8-1/2-month period
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