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Has anyone ever seen a 423 stock purchase plan with a match (e.g., for every 2 shares purchased by the employee, the company would

contribute an additional 1 share). Arguably, the 2 shares could be treated under 423, while the additional share would be treated under section 83. The concern is that the employee would be viewed as having purchased the additional share along with the other 2 shares, thus resulting a violation of the 85% requirement. Any thoughts?

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