He was 3.5% shareholder when it was sold to eBay in 2002, he was likely under 10% at the time the IRA made the purchase or shortly thereafter Director && % mus

He was 3.5% shareholder when it was sold to eBay in 2002, he was likely under 10% at the time the IRA made the purchase or shortly thereafter Director && % must be satisfied simultaneously The IRS enforces this and thats what they look for Nobody else is able to interpret that part of the law to cause an action