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From @Mike9241  I thought he meant contribution is tax free and I only need to pay tax on earnings.

From @dmertz  Since excess is coming from employer contribution, I need to pay tax on both contribution and earning.  

 

Sorry I am getting confused. 

 

I was also reading Publication 525 on "Excess Annual Addition" session.  (this shows code E)

A corrective payment of excess annual additions consisting of elective deferrals or earnings from your after-tax contributions is fully taxable in the year paid. A corrective payment consisting of your after-tax contributions isn't taxable.

 

My understanding from IRS rule : This is saying the contribution is not taxable.  only earning is.   Could you please help me understand this ?

 

Thank you