Taxpayers aren't bound by SBA opinions.  I would wait until IRS provides guidance, or Congress decides whether to enact legislation that explains what they meant.  Also, I wonder if "cancellation of indebtedness" rules apply here, for insolvent businesses.  The issue is not deductibility of expenses paid with a PPP loan, but taxability of partial loan forgiveness, when there was no obligation to spend the funds on anything else.