Those who accuse me of not playing nice at times, will be disappointed that I passed my Covid test Saturday at the Paris pharmacy across the street from the Airbnb, and after 24 hours and two flights yesterday I am trying to remember some of what I managed to forget about taxes the last couple weeks in Spain and France.  I have a client who sold S corporation stock back to the company -- but at a profit.  I was wondering if Section 1244 applied, but that's only for losses.  Might help your client, though.  Another client sold a medical practice, where insurance reimbursements often take six months or more to be paid after services are delivered.  I wouldn't call a settlement of these amounts "deferred compensation," but I would agree with putting it on a W-2 and telling the former owner/shareholder, "this is what you earned before you retired, we're just paying it to you now in anticipation of what we know will be collected later."