Loan Failure VCP and Schedule 5

[Briandfox]

Situation involves a plan with 2 loan failures.

Failue 1 can be corrected through reamortization because the 5 year term has not already expired.

Failure 2 cannot be corrected within the 5 year term and we are requesting that the deemed distribution be reported in the year of Correction as opposed to the year of the Failure.

The problem is Schedule 5 (Form 14568-E) does not accomodate both corrections on a single form.

I was thinking of either doing 2 separate schedule 5s for a single VCP filing, or not using schedule 5 at all and just drafting something individualized for this situation. At this point I am leaning to doing two separate schedule 5s, it just strikes me as a little counter intuitive.

Any thoughts on this would be appreciated.