A prototype document uses the IRS deemed standard reasons for hardship withdrawals. If an employee in a factory applies for a hardship withdrawal for pilot training lessons, is this permissible? The regulations don't define "post secondary eduction" and I can't find anything more definitive on the subject.

Since the plan document is a prototype I would suggest you contact the entity that provided the document (UPI, McKay Hockman, PPD, Corbel, etc.). They should have a legal consulting department that should be able to answer the question as it relates to that specific plan document.

If you are unable to go directly to the company that drafted the plan you should be able to go to the company which sponsored the plan document (TPA, CPA firms, broker, etc) and have them contact the appropriate entity.

For a takeover plan where cumulative deferrals since 12/31/88 are not available from the prior administrator, how are you calculating the amount available for hardship withdrawals?