For 401(k) plans should this line include participant distributions and plan contributions? Has anything been published to clarify this? My client's auditors continue to ask this question? Thanks for your help.!

Sorry I do not have a specific cite, but the auditors I have worked with are split down the middle, some say "a series of contribution deposits" constitutes a greater than 5% transation" some don't. I do know I have never seen this reviewed by an IRS agent on audit (e.g. either direction I've never had a problem). Not a great answer but maybe will give you some comfort.