On August 10, the Seventh Circuit allowed Verizon Communications to correct a drafting error in a tax-qualified plan that could have cost it over $1 billion. Young v. Verizon's Bell Atlantic Cash Balance Plan, 2010 WL 3122795 (7th Cir., Aug. 10, 2010). The court relied on the "scrivener's error" doctrine, which had already been endorsed by the Third and Eighth Circuits and a number of lower courts. Like those other courts, the Seventh Circuit held that the scrivener's error doctrine could be used to reform a plan only if (1) the error's existence is established by clear and convincing evidence and (2) there is no reasonable reliance on the drafting error on the part of the plan's participants. The IRS still does not recognize the scrivener's error doctrine, although it often will allow retroactive corrections of drafting errors in similar circumstances under the Employee Plans Compliance Resolution System (EPCRS).