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Retirement tax questions

The gift isn't an employee achievement award, though I appreciate the citation to actual law. I would look to 102(a), 102(c), 274(b), and the Duberstein case.

 

Again, the original poster should seek professional advice from someone who's thought carefully about these issues, and who can evaluate the specific facts and circumstances. The amount at stake is pretty large to give off-the-cuff advice.