Quote from GTC:
mss, If money is moved from one's regular account to one's IRA account, it is a contribution.
I agree with this but I am not sure I understand the point you are making. My point is that the maximum amount on which a penalty is computed under 4973 appears to be limited by the value of the account as of the end of the year. Under my understanding of the facts here, the value would be zero if Developer17 contributes no more than is necessary to cover the loss in his account.