Excise Tax for 2 years

[emmetttrudy]

Plan sponsor failed to make 2007 minimum required contribution which is $100,000. Excise tax due for 2007 = 10% * 100,000. Client froze the plan in 2008 to "stop the bleeding". Minimum required contribution for 2008 is $120,000, which is the $100,000 from 2007 plus an additional $20,000 shortfall installment. Plan sponsor made no contributions for 2008. Is the excise tax due for 2008 = 10% * 120,000, or 10% * 20,000? My understanding is that it is 10% of the entire minimum required contribution (10% * $120,000) even though a portion of the 2008 MRC is due to unpaid MRC from prior year. Is this correct? [For simplicity sake I am not taking into account any discounting that would apply to the $100,000 contribution from 2007].

[SoCalActuary]

Each year's tax is based on that year's failure to meet minimum funding.

So 2007 was a failure of $100,000, tax of $10,000.

2008 was a failure of $120,000, tax of $12,000.

If 2007 tax was not paid, then add on interest and penalties for failure to pay.