TRA '86 Nonamender and RMD Failure

[Christine Roberts]

MPP Plan for professional medical corporation was last amended for TEFRA, DEFRA, & REA in 1985.

Accountant for corporation has discovered failure of owner to take required minimum distributions over a 5-year period.

Presuming that both the amendment failure and the RMD error can be corrected through VCP, are two separate VCP filings necessary or can both problems be corrected in a single VCP filing?

[Alf]

Combine. I don't think you are eligible to file the second once you file the first, especially because the same years are at issue. I seem to recall that you pay the larger fee, but because the non-amenders are on a different fee schedule, you may have to pay both fees.