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Administrative Error - Calculations

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A client recently discovered an error involving the calculation of an employee's benefit under its NQDC plan. For example, an employee was paid 30,000 in 2008 (full account balance), but recently it was discovered that the employee should have received 30,200. Has anyone tried to correct this type of administrative error? 2008-113 limits corrections to 2 years. What is the penalty? Would this type of adminstrative error cause the employee to owe the 20% 409A tax on the entire 30,200?

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