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"IRS officials were asked whether an employee who is hired on January 2, 2012 would become a participant on January 1 or April 1, 2013 in a plan providing for entry on the first day of the calendar quarter coinciding with or immediately following completion of one year of service.... [An] IRS senior tax law specialist in employee plans technical compliance in effect indicated that the year of service would end on January 1, 2013 by stating that the employee would become eligible to participate on that date. This answer assumes that the service requirement is satisfied on January 1, 2013. Since that date coincides with an entry date, that is the date the employee should be eligible to participate."
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