NQ ESOP?

I have a question from an advisor regarding a NQ ESOP. I thought all ESOPS were QRPs. Perhaps they are referring to a Stock Option or Stock Bonus Plan.



I think their are circumstances where an ESOP can lose qualification. Perhaps something in this link will relate to the situation:
http://www.irstaxattorney.com/Tax-shelters/Announcement_2005-80.html



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