I have a takeover client that previously adopted a Volume Submitter document circa 1992. IRS auditor is asking for amendments required under UCA '92 and OBRA '94.

Even though he's now with me, isn't his document still maintained by the former TPA, who would have added these amendments to the Volume Submitter document?

Opinions? To my knowledge, client was never sent an "I'm giving you the boot" letter.