Help!!

I have a plan that begins 6/30/08 and ends 6/29/09. According to the regs, the "lookback" AFTAP is due prior to the first day of the 4th month of the plan year. I am not sure how to interpret this for this plan.

Is the "4th Month" October 2008, so it is due prior to October 1, 2008? Or, is the 4th month in September, and it WAS due prior to September 1, 2008?

thanks

Doesn't the fourth month begin September 30, 2008?

They're are many instances where it may seem unclear from the date rules how to proceed with this funky plan year. Rules that deal in months rather than days are always confusing. Unless someone can cite a reference giving specific direction, all you get from the response on a bulletin board is an opinion (which may be the right answer). The conservative approach will generally lead to your sleeping soundly.