NZtpa

No Penalty letters yet but a lot of letters denying extensions this week. We mailed 12/31/2021 extensions in bulk via certified mail that show with usps tracking that they were delivered prior to the 7/31 deadline. The stamp on the certified mailer back however shows a receipt date of 8/8. The IRS appears to be rejecting them all one by one as attempted to file late. They were postmarked and delivered on time. This appears to be a logging error with IRS where we now have to dispute timing. 12/126 have forwarded letters so far this week. Just waiting on the second wave for the late filer penalties. What a waste of time.

Hello, Plan originally covered 100% owner and spouse, exempt from PBGC coverage. They have since divorced but spouse has remained as an employee. No Minor children between them. Ex does not have options to stock under 1563(e). Does the 5 year look back for ownership purposes for PBGC coverage extend to owners by attribution during the last 5 years or is it only if they had 10% direct ownership on their own?