Sole prop DB plan tax isssues

[dmb]

If a sole prop set up a DB plan effective 1/1/05 and had a $200,000 deductible contribution for 2005, but did not have any self employment income in future years, but still had non-deductible contributions, upon plan termination would the entire distribution be considered taxable income or would only a portion of it be considered taxable since he did not receive a deduction since the initial contribution?? Thank you.

[Blinky the 3-eyed Fish]

There have been discussions on this in the past. My thought is that even though it's a sole prop, there is a distinction between the entity and the owner. The non-deductible is an entity concern and does not affect the owner and therefore there is no basis in the distribution.