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Just wanted to see if I'm off base here. It appears that since the new IRC 7528 was added and EGTRRA Section 620 was repealed, the waiver of user fees for determination letters (including plan termination) in certain circumstances for small employers is now gone, and that any such determination letters will be subject to the user fee schedule in 2004-8. (Effective 1-20-04) Agree/disagree? Comments? Thanks.

Ok - just looked at the actual code section, and not just the Revenue Procedure 2004-8. Even though EGTRRA 620 was repealed, the new IRC 7528 does retain the waiver of user fees...

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