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Guest STLGiant
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at the Missouri Association of School Business Officials, two IRS agents (one from Kansas, the other from Iowa) discussed serial loans. The fact pattern presented was what if the employee had multiple contracts with multiple vendors--making contributions to each, but only having a serial loan with one of the vendors. The IRS responed (incorrectly I think) that tif a participant in a public K-12 had defaulted on a number of loans with one vendor, and they deemed the situation a serial loan situation, that ALL the 403(b) contributions made by that employee to ANY vendor could be subject to FICA and Medicare W/H.

It was always my opinion that in the event of a serial loan, the only contract affected was that of the specific vendor contract(s) with the deemed serial loan. Yet the Service indicated that ALL contributions to ALL vendors would be subject to withholding.

Anyone want to take a stab at this?

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