Group:
In general, can a taxpayer/ESOP (retirement plan)
who is under audit, still voluntarily self correct matters
they deem need correcting?
We believe a former ESOP advisor failed to give
basic advice on paying off an ESOP note in a timely manner.
The TPA allocated stock based on an assumption
that the ESOP note was proportionally paid. ie. 20% of note
paid in yr 1 and TPA allocated 20% of stock.
Also, a former employee of the ESOP TPA may have failed
to account for one terminated employee.
However, client ESOP is under audit and I'd like to have client
file voluntary self-correction with Dept. of Labor and/or IRS EPCRS.
Anyone ever been successful in voluntary self correcting
while under audit? I note a taxpayer usually wants to
make the correction prior to an audit.
Thoughts and comments/resources/cases appreciated.
Stay Safe.
Warmest...