[This message is also posted in the DB message area]

I was wondering if anyone has insight into the following:

Company sponsors a DB plan. The plan was frozen July, 2000. The Company is in the process of filing for a GUST determination letter. The Company would like to file with the 1998 Form 5300 forms and not with the proposed forms. The question is must the entire Schedule Q (including demonstrations) be completed?

The instructions to Schedule Q provide that only Parts I and II need to be completed if "the plan does not benefit any highly compensated noncollectively bargained employees. " It seems reasonable to take the position here that this is true and that no further information is necessary.

Is this a position that the IRS will buy?

Thanks in advance!