I am asking not debating when I ask this. is this plan terminated? There is a resolution to terminate but in order for a plan to be fully terminated you have to have a resolution and all the assets have to be gone.
My first reaction is you can't file a final 5500 because this plan still has assets in the form of a contribution receivable. You have to resolve this issue and then you can say the plan is terminated.
Happy to be told otherwise but that is my first reaction.
Operational failure. After reviewing the document and the amounts involved, if it’s really 15 years, negotiating a solution under VCP would probably be the recommendation.