Phillip M. Wenger, C.P.A., A Sole Proprietor - Page 6




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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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