Deductibility of Contributions

[401_noob]

Hola Amigos!

I was wondering if anyone could point me to some guidance regarding the calculations of the deduction limit prescribed by IRC §404(a)(3) for an Employer that terminated their Plan mid-year, specifically if you use comp for the entire year, or just the portion of the year that the Plan was active.

I am inclined to say that it is for the entire year because I know that the deduction for DC plans is 25% of the aggregate comp of the eligible participants and that comp for deduction purposes is all comp paid or accrued to the participants during the Employer's taxable year.

I was hoping that someone would know where this scenario is described in the EOB or some other text. 

Thanks in advance!!

[BG5150]

Why would you want to destroy contributions?  ;)

[401_noob]

haha.. that should be deductibility!