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A Calendar yr plan is terminating effective 8/31/2003.

The valuation date is BOY (i.e. 1/1/2003) and the annual normal cost under the Ind Agg method is $100,000.

Per Rev Rul 79-237, for Section 412, Charges and Credits are pro-rated from BOY to the termination date.

So for the above, the minmum required would be $66,667 plus interest to EOY & late quarterly charge, if any.

Is there any such pro-rating requirement for determining the deductible amount S404(a)(a)(iii) i.e. deductible = Normal Cost + 10 yr bases' charges and credits = $100k +0 = 100k.

Your thoughts please.

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