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and thanks,

the reference in the 2001 Master Tax Guide in paragraph 2170, bottom of page 531, under the heading "Active Participant Defined". It would appear that in a defined benefit plan you are a participant if you are eligible,even if you opt out. However, for a money-purchase plan, a contribution is necessary to be considered a participant. I think the accountant is just misreading this section.

thanks again,

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