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Pro-Rate Shortfall on Short Plan Year DB Plan

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-DB Plan is frozen

-Short Plan Year from 10/1/18 through 12/31/18

-Plan has a shortfall of $100,000

Question - For the purposes of minimum funding, do you pro-rate the shortfall amortization charge for 12/31/118?

Please provide source/link/site.  Thank-you

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Short plan years were discussed in the proposed reg published in the Federal Register 04/15/08.  Also included in the final reg published in the Federal Register 09/09/15.  The latter can also be found in Internal Revenue Bulletin 2015-39, found here:  https://www.irs.gov/irb/2015-39_IRB.  Did your research agree with this?

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