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After reviewing EPCRS, it appears to me that if an employee is improperly excluded from the plan and is catch-up-age-eligible, in addition to making the missed deferral/match payments, you also have to make a catch-up contribution for an amount equal to 25% of the applicable amount (i.e. 25% of $5,500 for 2009), assuming the contribution amount does not exceed the participant's gross income (Section 415).

Is this correct?

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