Yep, I've got a copy, which you can view by clicking
here. Unfortunately, the ruling was not very helpful. It determined that the particular plan at issue constituted an excess benefit plan, and therefore that (a) the recipients would be taxed only as benefit payments were made, and (B) the trust itself would not be taxable. However, with respect to FICA taxes, which have been the most controversial provision, the IRS simply declined to rule until it issues regulations or other published guidance.
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Employee benefits legal resource site