Procedurally, the worst-case scenario will be if the IRS picks up the case for audit in October 2020, decides to impose taxes, and the company has to go through the protracted legal process before the issue is finally decided.
This is not a typical IRS commissioner debate. Over the last several months, the Trump aministration has weaponized the tax code to punish its political adversaries and benefit shadowy, far-right groups.
