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Group: I'm a new user to ftwilliam software. Even though I've drafted and worked with a number of S ESOP plan documents over the years. Ftwilliam seems to be one of a few firms in 2021 with an IRS Pre approval letter they received for their ESOP Plan document which was dated June 2020 from IRS. (ftwilliam didn't release the letter to users until Mar 2021) Even with the pre approval letter are you (as ESOP practitioners) still filing an application for determination of initial qualification (form 5300? 5307?)? Thoughts and comments appreciated.

In light of recent revelations concerning IRS practices over the past few years, I can't help but think I may have a client that's been similarly targeted. It's a Cycle E plan that was filed on the last day of the cycle (1/31/11). I've checked in with the IRS a few times to check on the status, and the last time I did so (early April, 2013), the plan still had not even been assigned to an agent for review. It's an on-cycle filing that's been sitting on a shelf for more than two years, and nobody's even looked at it yet. When I called, the agent I spoke with explained that this was just their normal timing and it wasn't unusual. I understand their queue is pretty backed up, and I get that filing on the last day isn't the best way to get a quick determination letter, but this still didn't sound right; particularly since the filing in question was sent in the same folder as half a dozen other filings; all of which have received letters at this point (some in less than a year from the filing date). I've yet to find an explanation for why plans are being treated so differently. But before I get too paranoid, I wanted to see what others' experiences have been. 1) Does anybody else have on-cycle Cycle E filings that have yet to be assigned to an agent? 2) Is there any non-tinfoil hat reason a Cycle E plan would be unassigned for so long? 3) Have you been getting letters on Cycle A plans, yet? 4) Has anybody else had clients with multiple filings that were treated this disparately? Any input/feedback would be most appreciated.