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Got it. Thanks guys. Tom Modesto, CA

Not if you also show as a disposition in the same year.

When the treasury lead says it is optional, and with no apparent rush to put out directions for employers and employees, the only conclusion is it is much ado about nothing. Unless it is not optional;, I see no reason to modify my software. Those that want to take the risk and defer can already do so my manually changing the calculated value. I do not want to make it easy for an employer to get into a debt situation. The one piece which struck me is how employers are required to withhold (existing rules), and how the memo only offers deferral of payment.