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The IRS says that you can apply the overpayment to a subsequent tax year without penalty within certain limits & with certain conditions.

This is unequivocably false, and my request for an IRS citation will yield nothing but "[fill in the blank] did it."

IRS mentions nothing about earnings when you just pay the penalty on the excess contribution because there's no requirement that you do anything about earnings in this scenario.

What someone gets away with and what the law provides are not the same thing. Think OJ.

Phil
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