Not that I know of, because of the clause we have in there that if they tried to do something like that, they do have to go back to pay the percentage of tax that was deemed to be there in the first place, the benefit, if you will.
Once you've run a business for five years, that is seen to be a very relevant amount of time, by the research we did, to be able to say that the transaction is obviously legitimate at that time. If it were sold back before that period of time and there were, as you say, a false benefit there or a deemed benefit, then there would be a penalty in place.