New Plan - Is Averaging Still Relevant?

[rocknrolls2]

Company X has established a new 401(k) plan effective Januaryu 1, 2008. A portion of the SPD has a section explaining the optional tax treatment of plan distributions (including averaging) and of course, there is the 402(f) notice. My question is, do we still need to refer to averaging since most of the people who could conceivably be eligible have since retired? Is there any conceivable set of facts by which an individual who was age 50 or older in 1986 could average today assuming plan-to-plan transfers involving several plans between 1986 and today? I know that in the case of plan-to-plan transfers, there are a number of private letter rulings concluding that, for purposes of the 5-year averaging requirement, the years of participation with the former plan could be tacked onto the years of participation after the transfer in determining whether the requirement was satisfied. Does this apply as well to eligibility for averaging in general?