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Initial short plan year prorate deduction?

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I have a DB plan that has an initial short plan year.  The effective date of the plan is 7/1/2018 and the actuarial valuation date is 12/31/2018.  Does the deduction for 2018 need to be prorated?

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33 minutes ago, shERPA said:

No, full amount should be deductible.  See PLASTIC ENGINEERING & MFG. CO. v. COMMISSIONER.

An amortization base payment is pro-rated since it is based on a period of time, but TNC for the benefit accrued for the plan year is not pro-rated. 

Thank you!  I did see this before on a previous post but I always tend to second guess myself and our actuary thought this was the case but was not certain.

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1 hour ago, AndyH said:

Why wasn't the effective date of the plan set as 1/1/2018?

Owner wanted to exclude employees terminated prior to 7/1/2018...

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