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Suppose you have a 1 participant DB plan for a small profitable employer with a 6/30 plan year end and 1,000 hour requirement for benefit accrual.

The plan existed for 4 years until benefits were frozen a year ago. Upon restating his plan on April 1, 2012 we unfroze the plan per his instruction effective for the plan year 7/1/2011-6/30/12. Now apparently he lost his largest client and wants to terminate the plan.

If the plan were terminated effective 6/30/12, could he accrue a full year of participation for 415 dollar limit purposes for the year 7/1/11-6/30/12?

Thanks.

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