QUOTE (david rigby @ Feb 12 2008, 05:07 PM)

The Rev. Proc. is not automatically repealed by PPA, but certain parts of it are overridden (such as the ability to adopt the aggregate method); that does not invalidate the RP. IMHO, Approval 13 is still valid.
Is there some reason or conflict that you think would interfere with this?
Mr. R's point leads to an interesting question: Given that now there is one and only one bonafide cost method, is the enrolled actuary still bound by the take-over provisions of 2000-40? I.e., is the actuary required to reproduce the prior year's results? What happens if you can't? In the past, I've usually been able to reproduce the prior actuary's results to a reasonable degree or explain why I can't. With the computational complexities introduced by PPA, I'm unsure how I would explain why I can't.