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Not enough information. How many participants? Is this 1 out of 100? Or 50 out of 75? Dollar amount involved? Etc., etc.?

Likely to be insignificant, but really no way to tell without full data. Take a look at the Revenue Procedure (2016-51 is the number I remember, off the top of my head don't remember the number of the updated Rev. Proc. - maybe 2018-52?) Section 8, which will give you some parameters. But it will often come down to a judgment call anyway.

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