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Posted

In reviewing a Schedule SB for 2012 for a CY plan, I noticed that there was a typo on the Valuation Date. It indicated 12/31/2012 when it should have been 01/01/2012. The numbers are all correct, but, it is just that this date was put in incorrectly.

Question: Should I amend the 2012 filings and re-submit or just let it go and if the gov't calls me on it, explain that it was just a typo and that would be the end of it?

Posted

Suppose you amend it and re-submit, which presumably you'd need to have the 5500 resigned? Then, in two weeks you find another typo. Then, next year you find another typo.

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

Posted

Would "the numbers" on the Schedule be the same numbers if the valuation date had been December 31, 2012?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted

Would "the numbers" on the Schedule be the same numbers if the valuation date had been December 31, 2012?

I suspect that that would be most unlikely. Would that make you lean towards amending the filing or towards not amending?

Suppose that the plan covered 100+ participants and beneficiaries, and a valuation date of 12/31/12 would have been impermissible. Would that make not amending the filing more reasonable or less?

Always check with your actuary first!

Posted

Caution. If the 2012 date was a typo, what was on the 2011 filing? If 2011 filing had 01/01/2011, then doing an amended filing might be easy and advisable. If not, then you are faced with a different problem (or two).

Consider asking this question of the IRS thru retirementplanquestions@irs.gov?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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