Is there any circumstance in which the top-heavy minimum would be base

[Guest joanna]

The top heavy regs. indicate that all years of service, except for plan years beginning prior to '84 and years for which the plan is not top heavy, are to be used for the top heavy minimum accrued benefit. However, in the audit guidelines of IRS Announcement 95-33, years of participation may be used only if benefits are accrued on participation. Is there any circumstance in which the top heavy minimum would be based on years of participation if benefits are accrued over all years of service?