combined plan deduction limit

[Gary]

A company sponsors a db plan and a dc plan.

The company contributes more than 6% of covered comp under DC plan thus the combined limit applies.

The amount contributed to dc plan above 6% is 20,000.

Say the minimum DB funding is computed to be 200,000.

Say the 31% of aggregate compensation is 150,000; so the minimum is greater than the 31% total limit.

The DB plan has a large pre funding balance of 100,000.

Presumably if the DB plan contributes the 200,000 it is deducted, but the 20,000 excess discussed above would not be deductible.

However, say the contribution made to the db plan is only 180,000 where 20,000 of pfb is used to meet funding requirement.

Note the 180,000 still exceeds the 150,000 or 31% limit.

Of course the 180,000 contribution to db plan is deductible.

Since the minimum funding was 200,000 does it follow that the 20,000 excess contribution to dc plan can now be deducted reaching the grand total of 200,000?

404(a)(7)(ii) says amount of contributions to db plan to extent it does not exceed minimum funding requirement.

So this seems to mean only the contributions to db plan are deductible in this case and not the excess dc contributions.

Any thoughts on whether the 20,000 to dc plan can be deducted?

thanks.