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We use AccueDraft for our clients' volume submitter plans and submit all of them for determination letters. If we have a new plan or an old plan that has been amended since the last determination letter, do we have until the end of the EGTRRA remedial amendment period to submit the plan (at least until 1/31/11 depending on the EIN)? I have read Reve Proc 2005-66. However, I am still not absolutely certain.

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