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New Plan for 2013 plan year - IRS Notice about missing 2012 filing


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Posted

Not sure how this one happened, but have a new plan established in 2013. Have already filed the 2013 initial 5500-SF filing, see no errors in filing (checked as initial filing, effective date 1/1/2013, assets beginning of year all $0). Plan sponsor received letter from IRS asking for information on the 2012 filing for plan #002 (number assigned to new plan). Did check to see on DOL EFAST search to see if plan sponsor had some prior plan 002, don't see any prior 002 filings (our firm has had plan 001 forever, 001 2012 filing in place).

Wrote response to IRS to check their records as erroneous notice. Given past experience with IRS sending out wrong notices on plan filings, just wanted to put this one out there in case anyone else starts seeing bogus notices on missing filings for years prior to the establishment of the plan.

Posted

Yes, went through every response on our PDF version and also what was shown on the EFAST search site. Nothing that would indicate that anything but first year for 2013. Given past track record with IRS sending out bogus notices on "late" non-late filings etc., wondering if this is yet another glitchy fishing expedition on the part of the IRS with bad database queries. Interested to see if anyone else starts getting any of these clearly erroneous notices.

Posted

Something like this happened to us. Turns out the client filed a plan number 002 (using your example) Form 5500-EZ years ago, that he even forgot. Many letters between IRS and plan attorney required to resolve issue.

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