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Prominent ERISA Attorney Questions IRS Decision to Implement Annual Plan Amendments (PDF)
Charles M. Lax of Maddin Hauser Wartell Roth & Heller PC 
[Opinion] Dec. 19, 2005
15 pages. Letter of November 18, 2005 from Charles M. Lax to Joseph H. Grant, Directory of EP Rulings and Agreements for the Internal Revenue Service. Excerpt: This letter is intended to more fully express my objection to the effective mandating of an annual amendment requirement for qualified retirement plans in Rev. Proc. 2005-66.
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