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We have an HCE (>5% owner) who is now in RMD payout status, i.e. 70 1/2 and said HCE asked if we can count the ADP refunds already paid in 2017 to offset (reduce) the RMD amount (total distribution) now payable.

Is this permissible?  And any IRS produced documentation would be much appreciated.  Thanks! 

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