Thank you for clarifying.  I am rule follower but I think principal is the more important to understand to make professional judgement.  As the US tax code is so complex, any rule has exception, exception of exceptions, and those will be again applied differently depends on how the tax court rule over certain cases.  I have studied very carefully about the S-Corp officer comp's reasonableness, but as my original question is based on a special provision of Rev 2013-30 and the timing issue is caused by law, but not by the taxpayer's choice of not to run officer comp through payroll.  I believe there should be court case govern this real life situation.  The QBI however, could be a loop hole there as it is a new law from December 2017.  I doubt any court case would have a chance to appear over that.  All in all, I think the rule you have pointed out did not take Rev Proc 2013-30 into consideration, and if you have any case law taking it to consideration, that would be very helpful.