One participant MPP plan

[Guest sugar daddy]

a doctor contributed the following amounts:

2001 plan year $30K 415 limit $35k

2002 $45K 415 limit 40k

2003 $45K 415 limit $40K

2004 $45K 415 limit $41k

2005 $44K 415 limit $42k

2006 $45K 415 limit $44K

Assuming his comp exceeded 401(a) 17 for each plan year, I have calculated he has over contributed by $17,000. Additionally, he never filed a form 5500EZ upon exceeding 100,000 in assets (2001 plan year). I am aware that the 5500 reporting can possibly be resolved by the proverbial tear stained letter. However, exceeding the 415 is a whole nutter matter. I suspect the plan would be disqualified for the plan years it exceeded 415. My question is: Should VCP be the method of correction for this plan and if so, should it be done prior to filing 5500 ez's?

Apparently his CPA told him that he could contribute a "catch up" contribuiton to his pension plan. And now after realizing his error, he is telling him that the statute of limitations has run its course.