EPCRS Success Rates

[austin3515]

I have always been of the opinion that the IRS's approach to this has been (to their credit), if you have the wherewithal to come in and admit you have sinned and are willing to pay the fees, that they will more or less "rubber stamp" your correction methods, especially if they are the sanctioned correction methods.

So I have a client (business owner) who during a transition from one vendor to another did not re-establish her loan payments. We just took over as TPA and discovered the error. Obviously, one of the principals for correction is that it has to be Employer Error. Have people had good luck with submitting these corrections? I know the hurdle is higher than it is with respect to employees. Again I come back to the fact that my employer just wants to do the right thing. Would you do an anonymous VCP in this scenario considering the tax implications if it is denied?

[Kevin C]

We've only done a couple of VCP submissions for loan issues. Neither one had any problems getting approved. They did check to make sure payments started on the new amortization schedule, but approval came shortly thereafter. One of those filings included two loans for owners.

[Belgarath]

Are you still within the original 5-year period?

[austin3515]

yes, still within 5 year period.