An ESOP was terminated effective September 15, 1997. Common stock was valued December 31, 1998. Terminated ESOP just received favorable determination letter with respect to termination. Document provides that distributions are based on anniversary date coincident with or immediately preceding date distributions are made. In light of Rev. Rul. 80-155, is an interim valuation required or can employer use valuation that is already almost 10 months old? Thanks.

Well based on info you gave, I would say that you could do the distribution based on the previous valuation, however you will need to do a follow-up EOY val and then do a second distribution, because I'm sure there have been gains in the last 10 months (well okay - I'm not sure about the gains, but perhaps loses - and you may not be able to cover those).

My suggestion would be to do the interim valuation - then distribute the balances.