IRA contribution due to Litigation settlement

My client transferred his IRA money into a company from Las Vegas that was offering to pay income to him for life. This was not a life ins. co. Within less than a year the company filed for Bankruptcy, so the client filed a lawsuit against the Insurance agent that wrote the business. The client has reach a settlement and wants to know if he can have this settlement put directly back into his IRA as a litigation contribution or some other form so he doesn’t have to pay taxes at this time? Is there a private letter ruling that he can refer to. What other options does he have? By the way he has to pay his attorney out of this settlement, will that be treated as a taxable distribution? Is there any way around that if it is considered a distribution?



If the investment was not made with IRA or qualified plan money because client had already taken an IRA distribution, the various PLRs issued about a decade ago regarding “restorative payments” may not apply. Did client receive a 1099R in the past reporting an IRA distribution that client reported on his 1040?

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