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Just a thought - I recall old 404 regulations would mention the adjustment to the asset for contributions deducted but not made. I always thought this was exactly for situation described in the original question. Here is also 14:18 from DB Answer Book Contributions to a defined benefit plan can be deducted for a taxable year if the contribution is deposited to the plan's assets no later than the due date for filing the tax return for that taxable year (including extensions). [ I.R.C. § 404(a)(6)] Although the deposit may be timely for deduction purposes, it may not be timely for purposes of satisfying the minimum funding standard. Conversely, a deposit may be timely for purposes of satisfying the minimum funding standard and may not be timely for deduction purposes. Example. Fred Flintrock is a sole proprietor and sponsors a defined benefit plan. If his tax return for 2000 is not on extension, he must make contributions by April 15, 2001, in order to deduct them on his 2000 tax return. If Fred makes the contributions after April 15, 2001, but before September 15, 2001, the contributions will be timely for purposes of satisfying the minimum funding standard for 2000 but must be deducted in 2001. Conversely, if Fred's tax return is on extension until October 15, 2001, and the contributions are made on this date, they will be timely for deduction purposes but not for purposes of satisfying the minimum funding standard for 2000. If the employer files for an extension of time to file its tax return and then files its return before the original filing date, the due date for deductible contributions is the extended due date. [ Rev. Rul. 66-144, 1966-1 C.B. 91] If, however the employer first files its tax return and then applies for an extension of time, the IRS has ruled that the extension is not valid for purposes of increasing the time for making deductible contributions to the plan. [ Ltr. Rul. 8336006] I think ERISA Outline has some example like this as well. So nothing against Gray Book 2011-7, but I like Effen's reply - it should be the clients/accountants call.