Yes - it feels like a long shot, but since the IRS intends for a >2% shareholder to be able to deduct their health insurance premiums I'm just trying to see if there's any way to cross the t's and dot the i's after the fact to help them get the deduction. It seems the answer is no based on notice 2008-1 and the replies on this discussion so I'll just make sure he gets this set up right in 2022