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Does anybody know how to go about using EPCRS to fix an impermissable premature distribution of a participant's 401(k) account? This is #5 on the IRS's list of top ten failures found in the VCP, but I can't find any discussion of how to solve the problem under Rev. Proc. 2006-27. I'm assuming the solution is repayment of the amount and a VCP filing, but I'd appreciate any authority. Thanks.

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