Guest Hanging In Posted July 13, 2007 Posted July 13, 2007 I have a client with a Prototype Keogh. The Prototype Sponsor dropped the client and no GUST or subsequent amendments were made. The missing amendment was found on audit (otherwise clean). The proposed sanction is $8,000. Section 14.02 of Rev Proc 2006-27 provides that minimum sanction is sanction under 14.04 for non-amenders found on DL Application. The GUST non-amender fee is $3000. This is new in 2006-27. I got an immediate (next day) rejection of an offer of $3500. Does anyone have any recent experience with Audit CAP sanctions for non-amenders?
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