3. The liquidating trust can not be an ongoing concern or it loses its IRS status. +++++++++++++ The plan trust have certain limit of existence but not a big concern on two different scenarios.
I. Total liquidation will put everything out if existence and therefore no longer needed to continue.
2. If new business is established, the business itself will self govern and therefore the plan trust will be out of the picture and just expire.
Although, I will not expect the number one scenario because the NOL will not be put into use.