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To confirm, an IRS audit couldn’t even come into play to review the situation if John does not sell the QSBS in his C Corp and continues to hold?  Or would an IRS review whether requirements of Section 1202 have been met in just the first five year period?   

 

In other words, while John holds per Section 1045, however the reqmts of Section 1202 were not met in the first five years, would he be liable for the capital gains taxes?