Can IRS user fees for determination letters be deducted from plan assets?

What type of determination letter is being sought? (ie.-plan term, initial document submission, GUST submission, etc.)

This is an opinion letter for an individually designed plan that is updating for GUST. I have done some research and in my opinion this is an expense that is necessary for continued tax qualified status. Therefore, it can be deducted from plan assets. I would like to hear any opinions that are contrary to my interpretation.

The DOL's "Guidance on Settlor v. Plan Expenses", hypothetical #4 says that fees paid to amend for USERRA and SBJPA (and presumably the rest of GUST) and obtaining a DL are legitimate plan expenses (assuming the fee is reasonable). It available on the PBWA section of the DOL web site.