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  1. A large payroll company (10,000+ payroll clients) marked box 13 with an X for a 401(k) participant who made no elective deferrals to the plan nor receved an employer contribution for 2019. There is no DB plan. So the employee received no employee or employer contribution into the plan account in 2019 nor was there any employer accrued contribution 2019. The employee was planning to do a deductible max IRA. the employer specifially told them - no X for this person. The Payroll company said because there were 401(k) loan payments they had to mark Box 13 with an X. That has to be wrong in my opinion. I gave them the IRS instructions on this with examples of no employee nor employer contribution but it doesn't say anything about loan payments - probably didn't think it needed to! Comments?
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