@dmertz wrote:
Because section 219(f)(3) creates the legal fiction that a contribution made for the previous year is deemed to have been made on the last day of the previous year, my current leaning is that the deadline was the due date of the 2019 tax return, which differs from the treatment being provided by the IRA custodian in this case. However, it's not clear that this legal fiction applies to section 408(d)(4) for a return of contribution.
Thanks. That IRC reference is what I was looking for. That seems to make it clear that Congresses intent was that contributions made by the due date are to be treated as if they were made in the prior tax year.
The IRS really needs to clearly say so in the pubs since even professionals get it wrong. (Not everyone reads the actual law that is much clearer than the IRS.)
**Disclaimer: This post is for discussion purposes only and is NOT tax advice. The author takes no responsibility for the accuracy of any information in this post.**
