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1992, the full funding limitation under sections 412 and 404 was
$40,729. For purposes of this case, under section
404(a)(1)(A)(i), the full funding limitation would result in a
maximum deductible contribution of $40,729 for the plan year
ending October 31, 1992.
Schedule B for the plan year ending October 31, 1993, showed
that petitioner made the following contribution to the TJM
Pension Plan:
Date Amount
January 8, 1993 $50,365
Based on the plan provisions and assumptions used by the
actuary for the TJM Pension Plan plan year ending October 31,
1993, the full funding limitation under sections 412 and 404 was
$52,443. For purposes of this case, under section 404(a)(1)
(A)(i) and section 1.404(a)-14(c), Income Tax Regs., the full
funding limitation would result in a maximum deductible
contribution of $52,443 for the plan year ending October 31,
1993.
During 1975, petitioner earned $12,895 in wages from
Fidelity; petitioner earned no self-employment income. During
1976 and 1977, respectively, petitioner earned $4,849 and $1,059
in net self-employment income from sales of Fidelity insurance
products. Petitioner had no self-employment income for the 1989
tax year. For the 1990 and 1991 tax years, petitioner reported
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