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Supplementing a VCP Filing


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I submitted a VCP filing on behalf of a client. After submitting the filing, it was determined that some of the corrective contributions indicated on the charts will have to be revised due to incorrect data. We have completed the revised charts and want to submit them to the IRS to become part of the filing.  Two issues:

(1) We have not even received an acknowledgement from the IRS. Should we send it anyway and ask them to replace portions of the existing material that was filed with the new material? Or should we wait until the IRS actually acknowledges our filing or has an agent send us a letter? What if the IRS approves the filing without any further action or change required on our part?

(2) We submitted the filing in February 2019, before the new procedure for faxing the filing became effective. If we supplement the filing, can we send the supplemental filing and its attachments via regular mail or should we utilize the new procedure of faxing it to the Service? Thanks.

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FWIW - I haven't had this situation, so just my thoughts. Since it has been more than 6 months, I'd first contact the IRS to find out the status. If they say it should be assigned in a reasonable timeframe, I'd wait until it is assigned. Otherwise, I'd send the corrections, with a cover letter explaining the situation, and a copy of the entire original filing, since it may otherwise never get connected properly.

I don't think you can utilize the new pay.gov procedure in this situation, where you have already submitted and paid. But once it is assigned and you have a specific agent to work with, you can ask them how they want you to handle.

Others may have had hands-on experience with your precise situation, and give you specific advice on what worked for them. Good luck.

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