Case Study · Restaurant Franchise · Houston, TX

Garza Management Company — Houston Sonic Drive-In Franchise

Gigi Garza's Garza Management Company operates a Sonic Drive-In franchise group in Houston, TX. On the public record, she describes the program as enabling "hundreds of thousands of dollars" in annual savings alongside meaningful benefits for employees.

IRS Section 125 — Federal Law Since 1978
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ACA · ERISA · COBRA · HIPAA Compliant
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ACA's services have enabled our organization to save hundreds of thousands of dollars annually while providing valuable benefits to our employees.

Gigi Garza, Garza Management Company
What this case study tells you

The structure that produced this result

Multi-unit fast-food franchise operations are some of the highest-W-2-headcount businesses outside of large industrial employers. A 10-location Sonic franchise with 25 employees per location is a 250-W-2-employee operation, which produces $170,400/year in FICA savings alone (250 × $681.60) before any restaurant-classification Workers' Comp reduction.

Gigi's quote — 'hundreds of thousands of dollars annually' — is qualitative on the record, which is consistent with how multi-unit franchise operators typically describe results when the actual figure varies across locations and depends on annual headcount. We don't substitute a specific number where the operator hasn't published one.

What's worth noting is the second half of her quote — 'while providing valuable benefits to our employees.' The Section 125 program adds 24/7 telemedicine, free generic medications, dental savings up to 60%, and mental health counseling for the household. In a restaurant workforce where benefits access is often limited, that's a real recruiting and retention value that an additional ~$72/paycheck reinforces.

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Darcy L. Hitesman, J.D.

HitesmanLaw P.A. · Minneapolis, MN

35+ years as an Employee Benefits attorney specializing in IRC Section 125, ERISA, HIPAA, and the ACA. Her May 5, 2025 opinion letter concludes: “In this firm's opinion, the Program described satisfies applicable IRS requirements.”

She specifically reviewed the IRS Chief Counsel Advice memoranda on "double-dip" arrangements — the exact schemes the IRS has flagged — and concluded this program is built differently and compliantly.

Named a Super Lawyer every year since 2000. AV-rated (highest possible rating) in Martindale-Hubbell since 1998.
Co-author: ERISA Compliance for Health & Welfare Plans (Thomson Reuters/EBIA) — the national compliance standard manual since 1999.
Member, Technical Advisory Group — Employers Council on Flexible Compensation. She helps set the industry standards for Section 125 plans nationally.

CBIZ Advisors LLC

Top-7 U.S. Accounting Firm · Cleveland, OH · 135,000+ Clients

CBIZ independently reviewed the program against IRC §§ 125, 105, and 106, plus ERISA, ACA, and COBRA requirements. Their August 22, 2025 letter concludes: “If operated per its provisions, the Program appears to satisfy the requirements of ERISA, the ACA, and COBRA as well.”

This review was commissioned by Affinity Hospice's CEO before enrolling his nationwide organization — and the CFO (himself a CPA) shared the letter publicly in his testimonial.

Top-7 U.S. accounting firm. 10,000+ employees across 100+ offices. Serves 135,000+ clients nationally.
Review covers: IRC §125 cafeteria plan, §105/106 wellness benefit rules, ERISA plan asset treatment, ACA integration, and COBRA obligations.
$500,000 legal protection per enrolled employer · $10,000 per employee participant · Insurance-backed.
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Direct From the U.S. Government

Section 125 has been in the Internal Revenue Code since 1978. Congress wrote it there specifically to encourage employers to fund preventive healthcare for American workers. This is not a loophole — it is the precise, intended use of a 47-year-old federal law, grounded in IRS Revenue Ruling 69-154, the specific published ruling supporting the benefit payment structure.

→ Verify on IRS.gov — Section 125 Cafeteria Plans ↗
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Verified: CBIZ Advisors LLC (Aug 2025) · HitesmanLaw P.A. (May 2025)
$500K legal protection per enrolled employer · IRS Section 125 · Federal law since 1978