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Yes, that is a failure to meet the requirement that it be a lump-sum distribution. In that case, the Form 1099-R should not have anything in box 6, no distribution of NUA, just an ordinary distribution of the shares which gives the shares a cost basis a short-term cost basis equal to the shar value on the date of the distribution, reflected in the gross-distribution amount.
‎April 13, 2025
1:52 PM