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In Rev. Rul. 2003-27, IRS Requires Basis Adjustments for ESOPs Holding S Corp Sponsor Stock
Internal Revenue Service [IRS] 
[Official Guidance] Feb. 21, 2003
Excerpt: HOLDINGS: (1) An employee stock ownership plan (ESOP) is required to adjust its basis in S corporation stock under § 1367(a) for the ESOP's pro rata share of the corporation's items. (2) Upon the distribution of S corporation stock by an ESOP to a participant, the stock's net unrealized appreciation under § 402(e)(4) is determined using the ESOP's adjusted basis in the stock.
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