2008 PLR on transfer of surplus assets

[Guest MAO]

I am trying to find out what firm/attorney submitted the PLR request that resulted in Private Letter Ruling 200836035, interpreting the 401(m) regulations as prohibiting the use of surplus assets to fund matching contributions in a qualified replacement plan. I am dealing with a similar issue and would like to find out as much information about the 2008 request and ruling as possible. Any ideas on how to find the author of this PLR request?

[jpod]

No idea how to find the attorney. If you haven't considered this, I know that in the "old days" you could file a FOIA request to get a redacted copy of the IRS' ruling file. Don't know if that's still done and if so how long it takes.