Deduction Timing

[12AX7]

Client filed their tax return on 4/15/09. The accountant forgot about the required contribution to the DB plan and didn't put the return on extension. Therefore, the contribution will not be taken as a deduction in 2008. Client is surprisingly not upset, however the question I have concerns taking the deduction in 2009 (for 2008 and 2009 contributions). How would this get coordinated? Thanks.

[Andy the Actuary]

Note: If you claim on 2008 SB, you will have different assets 2009 for 430 and 404 purposes. 430 assets will be greater than 404 assets. This will especially be fun if you are using an asset smoothing method as you would have to determine two different values, which for 2009 will likely just mean 110% of one versus 110% of the other.

[tymesup]

Hope it's deductible when they want to deduct it.

Hope the deduction pattern doesn't show up on audit radar.

Hope the accountant and client haven't forgotten anything else.

[Blinky the 3-eyed Fish]

Andy the A, what do you thing about these apples? 404(o)(2)(A)(ii) references "the value (determined under section 430(g)(3)) of the assets of the plan ....", thereby linking the asset value to the same as for the minimum contribution determination.