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Guest tcroscut
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I recently noticed that Form 5309, application for determination of employee stock ownership plan, was revised as of December 2004. The revisions are quite substantial in the portion of the form applicable to 4975(e)(7) ESOPs. Has anyone spoken to the IRS regarding whether the answer to all of the 4975(e)(7) questions must be yes in order to obtain a favorable determination letter? The plans I deal with do not contain provisions regarding the terms of the exempt loan and all have obtained favorable determination letters in the past. I am concerned that I will need to amend all of those plans in order to pass the form 5309 questions. Any thoughts?

Thank you!

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