Net Unrealized Appreciation (NUA) question/suggestions for tax benefits

Let's say a client, 40 y/o, was terminated and has $100,000 worth of company stock in an ESOP. The cost basis for the stock is $50,000, so the client has $50,000 net unrealized appreciation in the stock.

Let's also assume that the client needs to use $50,000 and he is in the 10% tax bracket.

The way I understand it, if the client takes a full distribution of the stock, in-kind, to a brokerage account, the $50,000 cost basis will be subject to an early-withdrawal penalty and treated as ordinary income immediately. If sold immediately, the $50,000 NUA will be treated as a long-term capital gain and is NOT subject to an early withdrawal penalty.

Question 1: If the stock is sold immediately after it is distributed to the brokerage account, can the client put $50,000 into an IRA such that it is treated as a 60-day rollover, and the $50,000 left will be treated as a long-term capital gain with an effective tax of 0% (10% tax bracket)? Basically, can the client have the best of both worlds?

Question 2: I've found some literature that says the client can roll $50,000 into an IRA directly from the ESOP, then distribute the other $50,000 to a brokerage account. Supposedly the rollover is treated as consisting first of the portion that is includible in gross income, so the $50,000 cost basis would be moved to the IRA. The $50,000 that is moved to the brokerage account will all be NUA, and the client can sell it immediately with long term capital gains treatment, effectively 0%. Is this correct?

Any previous experience with NUA would be greatly appreciated. Most of the literature I've found discusses absolutes of either a full liquidation or a full rollover, but nothing in between. These are the two most helpful things I've found...

LINK /

LINK