Ghost of Participant Past Redux

[Medusa]

We have a participant coming forward who in 1992 received a letter from the Social Security Administration saying that he was owed benefits by this client's plan. We have no record of this person or his balance, nor does the company, but presumably at some point in the distant past his name was put on an SSA. Of course that would have been several trustees and several TPA's ago. We don't even know when he supposedly worked there.

Does anyone know whose burden this is, in terms of the participant vs. the employer? Does the employer have to prove that the person was paid, or does the participant have to prove that he wasn't? It has been proposed to force the person to provide copies of all his tax returns to accomplish the latter, but somehow I don't think that would fly. It would be nice to be able to get a copy of a 1099R for the person, but I don't even know from when it would be, or whether the IRS keeps them for that length of time.

[MGB]

The burden is on the participant. Note that the letter from the SSA does NOT say they have benefits coming. It only says to check with the former employer because they MIGHT have benefits coming.