Why can't you impute disparity to QNEC's?

[austin3515]

I know you can't but I can't find it in the Code or the Regs. For example, 401(k)(12) clearly states that the SHNEC's can't use integration. Further, 1.401(l)-(1)indicates that contribtuions described in 1.401(k)–1(g)(3) are not eligible for integration, but this defintiion does not include QNEC's?

I'm driving myself nuts trying to find it...