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Text of Rev. Rul. 2004-4: Prohibited Allocations of Securities in an S Corporation (PDF)
Internal Revenue Service [IRS] 
[Official Guidance] Jan. 23, 2004
13 pages. Excerpt: In the three situations described below, (1) are the individuals disqualified persons within the meaning of § 409(p)(4) of the Internal Revenue Code (the Code), (2) does the related employee stock ownership plan (ESOP) have a nonallocation year within the meaning of § 409(p)(3), and (3) are any disqualified persons treated as owning synthetic equity within the meaning of § 409(p)(5)?
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