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I think it might be a little semantic difference: The advice to contribute to the 401(k) is based on what Pixy 'expects'. Certainly most funds in 401(k)'s will lag the market, but with the match, and an average of 12% for stocks, you can easily expect 11 or 12% or even more for your 401(k) returns. The discussion here was about what you 'plan' for.

Personally I subscribe to 'plan for the worst, hope for the best' when making plans.

When making tradeoff decisions 401(k) vs. taxable, its more prudent to do the calculations with the returns you expect.

Just my thoughts on the difference, I hope I didn't misunderstand your question.

Personally, in my PLAN, I don't even put company matching in the spreadsheet, I consider that part of the rate of return, of course, I contribute the max to my 401(k) because I do expect to get the matching at the end of the year. And the tax avoidance provides wonderful savings at the end of the year.
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