S corporation and a disqualifed plan or CAP (Closing Agreement program); how does the flow through nature affect either the loss of deduction on the

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S corporation and a disqualifed plan or CAP (Closing Agreement program); how does the flow through nature affect either the loss of deduction on the tax form or the MPA (Maximum Payable Amount)? Please provide reference to official source.

How does this affect the deduction flowing through to the tax return of the recepient of the S corporation's effects?