We have a client who, in his late seventies, started a business that is now sponsoring a DB plan. There are no other employees. His NRA is 83. Will putting 83 on line 6b of the Schedule B practically guarantee an audit? The doc defines NRA as 65 and 5P, but it's my understanding that you have to put the actual average age on line 6b. Does anyone have a different interpretation?

I agree that 83 is the proper entry for the Schedule B. Who knows what would "guarantee an audit"? More likely is that someone at the IRS would ask a question, of the EA probably, which could be answered just as you have stated.

P.S. Does the plan vest upon death?
P.P.S. Does this plan sponsor want to adopt me?

Pax - the benefits do vest upon death which may make things interesting should the unfortunate occur. By the way, they're currently considering my request for adoption - I'll let you know if it falls through. Thanks for your help.