412(i) plan contribution for a short plan year

[Guest Carol the Writer]

I have a 412(i) client who is being audited by the IRS. The auditor asked for the "promoter's" original proposal. Here is my problem. It appears that the first-year contribution was made based on the proposal. However, the proposal provided for a 12-month plan year. We, at our client's request, drafted the plan to provide for a 9-month initial plan year.

The plan sponsor is a charitable foundation, so it is tax-exempt. But does anyone have any ideas about what the IRS is after, or what I can do for my client at this point? Any suggestions would be appreciated. Thanks!