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Scuba 401

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client started a 401(k) in the same year and also excluded employees from a member of a controlled group.  VCP says basically for the first issue you just file the vcp and ask the IRS to allow the contributions to stay in the plan.  However you also have to  deal with the people you excluded and make a corrective contribution.  Would IRS want you to make a corrective contribution for the improperly excluded employees to a plan the employer shouldn't have had?  

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