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Regarding the special treatment of an employer's stock
in a lump sum distribution from a 401k plan: ie, election to take net unrealized appreciation
without taxes owed & capital gain treatment for subsequent sale.
Question: If the entire 401 k stock was distributed first into an IRA rollover, can the NUA &
cap gain treatment still be applied to a lump sum distr from the IRA?

As already pointed out you convert any possilbe long term gain into ordinary income, including the NUA if you roll over into an IRA.
Instead of paying ordinary tax on the distribution, however, if you were born befor 1936 you can use 10 year averaging on the exercise price which is a lot lower than your ordinary tax bracket. Ed
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