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MP and PS plans not restated since 1999 adoption


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New client adopted MP and PS plans in 1999, moved the money a couple of times, and never restated them.  Surprisingly, everything else looks pretty much ok - he's actually been entering 5500 info online and filing directly.  Two participants in each plan - father and his daughter, who is term'd.

Any thoughts/experience with maybe merging the plans now and submitting a VCP filing as one plan?  Over $500K in each plan; $3000 fee per plan...

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This reminds me of an issue I had - MP and PS plan was established.  The story was the plan documents were destroyed in a fire.  They had fired their provider at some point along the way and were handling the administration internally.  Their old provider had no plan document on file when I called due to their record retention policy.  However, the Forms 5500 were being timely filed and everything else looked ok.  The big issue is the fire destroying the documents happened years ago and there was no attempt to restate the documents over the years.  It was filed under VCP (although not anonymously).  I believe the plans were merged prior to filing.  It was approved after a lot of back and forth.  I remember an IRS agent contacting me asking what exactly I was trying to do.  They weren't following the narrative of the fire, etc.  It was interesting.  In thinking about it, anonymous may have been the better way to go, but it worked out in this case.

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3 hours ago, Belgarath said:

Why not submit as an anonymous VCP filing with what you propose? If it works, great. If it doesn't, you aren't any worse off than before?

Because I hadn't thought of it?

Thanks for both replies!

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