Here is just a quick note.
This is a great summary by FMV Opinions of Flemming Cardiovascular, P.A. vs. Commissioner released November 23, 2015 where the court found in favor of the IRS. The court determined that the ESOP did not follow its governing documents. This puts taxpayers on notice that if the owners of the firm do not carry out their roles properly, the IRS can and did revoke the taxpayer's ESOP plan and tax exempt status. That is a major "ouch." I want to thank FMV Opinions for staying on top of this and for providing a nice concise timely commentary.
Happy Thanksgiving!