An employer sponsors a DB plan, and makes the section 404 maximum deductible contribution to the plan, but spreads it out over the year (i.e. 2001 contribution made over 2002). Some of the contribution will be made after the due date for the company's tax return (9/15) and therefore not be deductible. Let's say the company has cash flow reasons to do this, and the 412 minimum is timely deposited by 9/15. Does this escape the section 4972 excise tax, in that it is not more than the "allowable" amount for the year? (The company plans to deduct the "extra" amount for 2002.)
