415 Final Regs - how do you measnure 2 1/2 months

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I have read the final 415 regs and do not see where 2 ½ months is defined. Has anyone seen any guideance

[John Feldt ERPA CPC QPA]

Here's how the IRS might answer: You define the 2 1/2 months by measuring it from the day the participant severs to a date that is 2 1/2 months later. I'm doubting that helped.

This is only important for employees that terminate less than 2 1/2 months before the end of the plan year, because the regulations allow you to go to the later of the end of the plan year or 2 1/2 months after severance.

I'd argue that a half month is 15 days:

Terminates November 20, 2007: 2 1/2 months = February 4, 2008?

Terminates December 20, 2007: 2 1/2 months = March 6, 2008?

Perhaps if the final 1/2 month is entirely in February during a non-leap year, the IRS might argue that it's only 14 days. Only the oracle knows.

[zimbo]

In the instance where an employee terminates, for example, on November 30th and has compensation creditable for 415 purposes that is paid in January of the following year, to which limitation year is that comp attributed for purposes of ADP Testing, Contribution allocations, TH minimums, HCE status and any other purposes for which the plan uses 415 comp?

In other words, if term date is 11/30/2008, and credited comp is paid in January of 2009, is it 2009 comp or 2008 comp or is that a plan document choice?