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In a mid-year asset sale where a portion of a profit sharing plan is spun-off to an unrelated buyer that results in no severance from employment, does the 401(a)(17) limit need to be prorated? Seller is making contribution to its plan on account of service prior to closing (so 10/12ths of the accrual), and the Buyer is contributing to a mirror plan for the post-closing accrual (2/12ths).

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