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That concept raises a interesting idea relating to ginormous retirement plan balances and Roth conversions in the one or two years immediately preceding retirement from salaried employment.The 401K is not the issue. They don't care how you got the money.
They care if you have a qualified appeal scenario.
So if he took the 401K money in 2023 AND has an appeal reason AND projects a lower income in 2025, he's golden.