I came across this blog and have found it extremely helpful with this general topic. A lot of good posts. My question is related to the 6-year SOL under 6501(l)(4) and the 6% excise tax under 4973(f). So I have someone who made excess Roth IRA contributions say over the last 20 years that we are looking to proactively fix. So under the 6-year SOL statute most of those years are closed. But for the years that are open, query if the “excess contributions” that include prior year excess contributions include those made in closed years. Or said differently, do those “excess contributions” made in now closed years have to be withdrawn to avoid the 6% excise tax. My take at the moment is that the SOL simply means that the closed tax years can’t be assessed. It doesn’t mean that in an open year where 4973(f) is being assessed that “excess contributions” as that term is defined but made in now SOL closed years can be excluded. It seems like the IRS needs to clarify this, if for no other reason than address the Form 5329 instructions for Part IV, line 18. In other words, if the first Form 5329 we file to fix the problem just goes back 6 years thanks to the new SOL rule, there would not be any ” total excess contributions” reported on a prior year Form 5329 to roll forward since prior year forms would not be required as those years are now closed. [I spoke with the IRS general tax law area this was the first they heard of this question/issue. They wrote it up for their subject matter expert and said to expect an answer in about 30 days.]