Exceeds the reasonable needs of the business and essentially tax is being avoided. I have no doubt they would be capable of doing that at some point but like I said I’ve never seen them impose or argue for it. My guess is that is something they tack on when they are mad about something else but what an argument to have.

IRS: this exceeds the reasonable needs of your business
Me: I’m saving up to acquire a competitor (or buy a new building or whatever)
IRS (or tax court): ok