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Plan fails 2019 ADP test, but refunds never done.  Correcting now under EPCRS using the one-to-one method.

Are the refunds still considered "late" and therefore subject to the 10% penalty tax?

Are they late in filing the 2019 5330 and thus subject to more penalties?

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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