I believe you are wrong. From the law: (1) The term "qualified small business" means any domestic corporation (as defined in Section 7701(a)(4) of the Internal

I believe you are wrong. From the law: (1) The term "qualified small business" means any domestic corporation (as defined in Section 7701(a)(4) of the Internal Revenue Code) which is a C corporation if all of the following apply: Because the act explicitly qualifies that the exemption applies only if ALL conditions are met there is no question of legislative intent or judicial remedy that could be applied. There is no possibility of "revised terms" because that would mean essentially rewriting the statute to make some conditions optional, which was not the intent of the law. Thus the entire statute(18152.5) is unworkable as explained by the FTB: https://www.ftb.ca.gov/law/Qualified_Small_Business_Stock_and_Cutler_Decision.shtml https://www.ftb.ca.gov/law/Qualified_Small_Business_Stock_an...