Quarterly penalties (Again#!?#?$?@)

[FAPInJax]

This is a short plan year question. I found the other threads but they did not appear to have a definitive answer (probably because there is not one).

Plan year 10/1/2004 through 12/31/2004

My thought is that the only payment date is 1/15/2005. This is 15 days after the first quarter (kind of).

Alternatively, the full plan year would have been 1/1/2004 to 12/31/2004 and therefore dates of 10/15/2004 and 1/15/2005 would fall after the initial effective date.

What about if the plan year was 9/1/2004 through 12/31/2004??

a) 12/15/2004

b) 10/15/2004 and 1/15/2005

Any opinions??

[rcline46]

Well, I agree with the 1/15 quarterly date. If 9/1 you have only the 12/15 quarterly date.

However almost everything else is a matter of conjecture as our friends at the IRS cannot figure out how to make it work. Neither can they quite figure out what to do with the succeeding full year! They just say make a reasonable interpretation.

With the paucity of recent audits and dearth of DB plans bet a short year has never been audited. Would also bet against them auditing a short year unless the B had some required audit triggers on it.

IMHO, of course.