I bleeve somebuddy on RB mentioned a LOOOONG time ago that the way these guys would be gotten was by the IRS, and no action would be taken until at least three years had passed from their filings of he returns for the relevant dates.
I bleeve the same exact thing will happen to many other compenstaed stock promoters - includin those from West Texas, Arizona, Florida, etc. Butt there will be a few years offset in time to capture their PP selling/commission activities right up to the end.
Makes it hard to explain the no cost basis shares or extra incentive discounts for the giftees/promoters.
Gee, I wonder who the Regional Counsel, IRS Southwest Region, Dallas, would be........ hmmmmmmmmmm.