Are One-to-One contributions treated as QNECs?

[Trekker]

Employer is correcting 2003 and 2004 failed ADP test using VCP. This can be corrected either with QNECs or with the "one-to-one" method (distribute then contribute). Are the corrective contributions in the one-to-one method treated as QNECs, in which case they could go toward satisfying the top-heavy minimum contribution (also failed in 2003 and 2004)?

The Rev Proc does not use the term "QNEC" in its description of the one-to-one method, but I've seen commentaries that refer to the "one-to-one contribution" as a QNEC.

Any thoughts or cites?

Thanks.

[Tom Poje]

This is a top secret file I discovered on the following website:

www.irs.gov/pub/irs-tege/401k_mistakes.pdf

Shhhhhhhhhhhhhhhhhhhhhhhh. don't tell anyone.

Though you do have a reading assignment (page 22 hint, hint, hint) and report back the answer to the question you posed.

[Trekker]

Ah, "in the form of a QNEC" seems to be the fine-print answer.

Thanks for sharing the secret file. I burned after reading.