I have a client whose 1996 5500 filing showed plan number 003 (Money Purchase Plan). The plan was amended to an ESOP and the prior recordkeeper files the 1997 5500 as plan number 005. The 005 plan number has been used since 1997.

BOTH determination letters issued 6/23/1997 and 2/11/2000 reflect the 004 plan number.

The plan was audited by the IRS (they said nothing).

What should we do?

(Perhaps make the change on the 5500 question #4?)

I would want the correct plan number on the current year return if i was preparing it. But as you suggest, you want the IRS to be able to track the filings. Ideally this would be done by going back and amending for the errors on prior returns. But they generally aren't going to do that. So the next best thing would probably be to show a change on the current year 5500 (I presume that is Q #4 but I don't have a 5500). But I would let the client know that is not the right way to fix this problem.

Tell the client to make sure everything matches with the right plan number (e.g., SPD, typed Schedules attached to return -- assets held for investment and reportable transactions, SARs, etc.)