On January 5, 2010, the IRS issued Notice 2010-06, 2010-3 I.R.B. 275, permitting taxpayers to voluntarily correct certain failures to comply with the documentary requirements of Code Section 409A. Section 409A governs non-qualified deferred compensation and the failure to comply with its provisions can result in immediate inclusion of such deferred amounts in the income of the service provider (i.e., the employee), a 20% excise tax and interest penalties. Notice 2010-6 provides a way to correct many—though by no means all—plan document deficiencies. Some of the relief is conditioned on making corrections by December 31, 2010.