Does anybody know of an IRS ruling (or other IRC law or regulation) that limits an employer's buy-back of accrued vacation time (PTO) to 90% of the face value of the benefit? A client of mine received a copy of a soon-to-be subsidiary's policy regarding the employer's purchase of accrued vacation time, which limited the employer's liability to 90% of the total accrued amount, based on a memo from its law firm, indicating that IRS rules require this 90% limit. I haven't been able to find this ruling in any of my research. Does anyone have any suggestions for me? Thanks!