I have a client who faxed wire instructions to their financial institution to make a $900,000 profit sharing contribution by the due date of their extended tax return (September 15, 2000). The financial institution failed to execute the wire transfer on the 15th. Instead, the wire was done on the 18th. Does anyone know if this contribution is deductible? I am leaning towards advising my client to deduct the contribution based on the constructive payment and agency relationship rules.
Any help would be greatly appreciated!