"A client just received a letter from the IRS about their 2018 Form 5500. The number of participants at the beginning of the year was 15, and at the end of the year was 10, which is a 33% reduction... but the reduction was due to terminated participants who took their distributions. The 20% number for a presumed partial termination is in regards to turnover, which means a lay off of active employees, right? What's the IRS doing sending letters and scaring sponsors over this?"