The participant count for a newly established plan at the beginning of the year was 119.
The independent auditor who was hired to perform the financial statement audit for the plan insisted that this new plan must file as a small plan and doesn't need audit.
My understanding is that the 80/120 rule is not applicable to a new plan if the the number of participants is over 99 for the 1st year of the plan.
The 2014 Edition ERISA Outline Book page 13A.76 states:
"Must have at least one year where participant count is below 100. This exception is not applicable to a new plan which starts with a participant count above 99. A plan must have at least one year with a participant count below 100, where it is eligible to file as a small plan filer, before it can use this exception when the participant count rises above 99."