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What are your thoughts on COBRA notice failures that are not willful and are corrected within 30 days, so no excise tax, and still reporting $0.00 excise tax on Form 8928?  


I am concerned because if we do not file one then no statute of limitations will apply.  So I am considering filing the Form with $0.00, but have multiple (many, many) failures.  Do you file a separate Form 8928 for EVERY participant that had a failure?


Thank you for your help!

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