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Partial Rollover from Plan Doesn't Preclude NUA Treatment on Stock That's Not Rolled Over (PDF)
Internal Revenue Service [IRS] 
[Official Guidance] Oct. 29, 2002
5 pages; PLR 200242052 (July 30, 2002). Excerpt: Neither the Code nor Income Tax Regulations promulgated thereunder, preclude a distribution from being treated as a lump sum distribution under Code section 402(e)(4)(D) for purposes of Code section 402(e)(4)(B) even if a portion of the distribution is rolled over into the Trust attached to another qualified plan.
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