Another Question about the potential of IRS Whistleblower award legal fees being excluded from income on the California 540

The consensus has been that it can only be used as an itemized deduction, up to the fed limit, which is not very helpful with a sizable award. The attorney has advised that it could be treated as a partnership since there was a contract between him, and the client executed 10 years ago. The attorney, is of course, reporting his share, and paying the appropriate tax, so the client should only report his share. Any validity to this approach? Has the concept been tested? Thanks.

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