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IRS Elaborates on 1990 Ruling on Deductibility of Contributions for Post-Taxable-Year Comp
Internal Revenue Service [IRS] 
[Official Guidance] June 28, 2002
Revenue Ruling 2002-46. Excerpt: Rev. Rul. 90-105 holds that contributions to a [401(k) plan] ... are not deductible by the employer for a taxable year, if the contributions are attributable to compensation earned by plan participants after the end of that taxable year.... The facts in this revenue ruling are the same ... except for the addition of [a] plan amendment and [a] board resolution setting a minimum contribution for the plan year. These factual differences do not change the result.
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