Incorrect TIN used for years on Schedule P

[Belgarath]

Just discovered a plan for which, reasons unknown (yet), the Schedule P has used an incorrect Trust Identification # going back at least 10 years.

Question - would you go back and file amended returns for all years, or just correct on a current basis? (EIN on the 5500 itself has been correct every year.)

I don't know if a P with incorrect TIN will fail to start the Statute of Limitation running for those years?

[Bird]

I would just fix it going forward.

[Belgarath]

Thanks. Naturally, that's my inclination as well, since it is a whole lot easier! I'm hoping that no one can think of a compelling reason to do otherwise.

[MarZDoates]

Same issue has come up with us. Except it was discovered on a Form 2848 Power of Attorney that the EIN does not match the plan. Plan is under IRS audit for pye 12/31/02.

What to do?

[saabraa]

Are you asking whether IRS can audit years prior to 2002, in this situation? If so, I've never heard of that happening. My experience has been that filing the basic 5500 itself, with or without the Schedule P, suffices to start the running of the SOL.

The prime piece of information on Schedule P is the trustee's signature. As for the trust EIN, the instructions to Schedule P tell you to enter the trust i.d. #, IF YOU HAVE ONE. For many plans, the number falls off the IRS system within a couple of years, when no money's been transacted to IRS under the number.