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An individual serves as an outside director for many corporations and sets up a Keogh plan to defer a portion of his directors' fees. He defers an additional portion of his directors' fees with the corporations for which he is on the boards. Assuming this individual receives $50,000 in deferred directors' fees in 2002, can he defer a portion of such payout into the Keogh plan? With common law employees, it is clear that the receipt of deferred compensation may be treated as compensation for 415 purposes. See Reg Sec. 1.415-2(d)(3)(i). For self-employed individuals, there is a cross-reference over to earned income. However, I am unaware of any exclusion from earned income of deferred compensation received. Any thoughts?

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