S-Corp ESOP Distribution - "Immediate Put"?

[Übernerd]

S-Corp ESOP currently provides for cash-only distributions (i.e., employer stock is in all cases liquidated within the plan). Employer would like to amend the plan to allow participants to elect a distribution in stock, subject to a requirement that the stock immediately be sold back to the ESOP (the idea being to allow participants to get capital gains treatment, rather than ordinary income treatment, on part of the distribution). Is there any problem with the "immediate put" requirement?

The relevant Code Section--§ 409(h)(2)(B)--isn't clear on this point (or any other--boy, what lousy drafting), and nothing the IRS has said seems to directly answer the question. There's some close-but-no-cigar guidance in Rev. Rul. 2003-27 (NUA for shares distributed from an S-Corp ESOP) and Rev. Proc. 2004-14 (permitting rollover of S-Corp shares to IRA if plan requires immediate repurchase).

Thanks.