Note:

You will not have an entry in the tax chart on the face of the L2005 for IRC 4975(b) tax for prohibited transactions. The potential for the 4975(b) tax is mentioned in the RAR, and you will utilize selectable paragraph 1 to make the taxpayer aware it could become due. The 4975(b)-tax paragraph 1 notification is for their information only at this point. The year the 4975(b) tax is due is not known until we go through the entire unagreed process, and the 90-day statutory notice letter is mailed by Mandatory Review. Hopefully, seeing the paragraph 1 notification and mentioning it may become due in the 30-Day Letter RAR will help to secure an agreement for correction.

The 30-Day Letter package for a proposed revocation/non-qualification includes:

Letter 1756 (Proposed Non-qualification/Revocation). See Employee Plans Examination Exhibits.

Pub 1

Pub 594

Pub 1020

Explanation for Proposed Non-qualification or Revocation (RAR)

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The 30-Day Letter package for a claim disallowance without additional taxes includes:

Letter 3602 (This is an EO letter, and we will use it for EP)

Form 2297 (See Employee Plans Examination Exhibits for an example of Form 2297)

Form 3363 (See Employee Plans Examination Exhibits for an example of Form 3363)

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The 30-Day Letter package for a claim disallowance with additional taxes due includes:

Letter 3602-B (This is an EO letter, and we will use it for EP)

Form 2297 (See Employee Plans Examination Exhibits for an example of Form 2297)

Form 3363 (See Employee Plans Examination Exhibits for an example of Form 3363)

Form 870-EP (Used when additional taxes are due. See Employee Plans Examination Exhibits for an example of Form 870-EP)

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