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I have a case where a 2009 contribution range of $100,000 - $500,000 is generated but the Sole Proprietor only has earned income of $200,000. A contribution of $400,000 would hit his PVAB for a maximum distribution.

The plan will be terminating by year end 2010.

Is it possible to fund $400,000, deducting only $200,000 in 2009 and then deduct the rest in 2011 & 2012 when he has income to deduct it against. (By a quirk, the Sole Prop will have $0 earned income in 2010, but will have income in 2011 & 2012.)

Any sort of direction/code reference where I could look it up would be great. I have been through 404 but do not see anything about it.

Thanks

CBW

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