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Client is surviving spouse. We believe her to be the beneficiary of a large account held in a "PSP." Husband and his attorney are both deceased. Life insurance salesman who sold them on the nonstandardized plan created by life insurance company is senile. Only papers related to plan date back to 2000. Those include some 5500s. We have contacted the insurance company and it cannot produce the nonstandardized plan, let alone the adoption agreement. We don't think it will ever be capable of being reproduced. Likely that the plan just went totally silent after about 2001, but no contact we can find in deceased's files from the IRS. Further, the small 3 person company that sponsored the plan is no longer and no one can be found. The investment firm holding the account says, "produce the plan document" before it will do anything. No plan document exists. What to do? One take I have is to say, "There is no plan document, hence, it's a after-tax account. Make a distribution and don't report on a 1099-R. I've read in this forum about the King case and the issues of "consistency" but, if I can convince the investment firm that it is an after-tax account, perhaps they would distribute the account to the surviving spouse. I do have an issue with not having a beneficiary designation, it appears. But, I do have a letter from way back from the attorney indicating that the deceased husband's revocable trust is the beneficiary. The King case might allow me to argue that if the plan went out of compliance from the get go due to lack of a document, that cash contributed was taxable in a closed tax year. And, now, the distributions are tax free from the account. We can't establish that a plan ever existed but there are just a couple of returns that the deceased attorney prepared (1997, 2000 and 2001). Nothing after. We have exhausted our search and I have concluded no documentation will ever be found. Thoughts?