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I have 4 plans merging into 1. All 12/31 PYEs. All memebers of the controlled group for all of 2012.

Plan A & B merge effective 10/1/12. We believe plan A is going to be considered the surviving plan. Plan B was a safe harbor plan.

Plan C merges in effective 10/2/12. Plan C is also safe harbor.

Plan D will merge in effective 12/31/12.

Surviving Plan A is not a safe harbor plan.

Quesetion:

Are Plans B & C considered Safe Harbor from 1/1-merged date? Or since it was a short plan year, do they lose SH status?

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