Undo 401(k) rollover check made payable to Roth IRA?

Individual was trying to do a rollover from his 401k (traditional) at Fidelity to an IRA at Vanguard.  His CPA told him to do it to Roth and pay the taxes.  The amount of the account is $300k and the CPA (unbelievably) did not make him aware of the tax consequence. The check was issued 4/22 made payable to his Vanguard Roth IRA, but has not been sent to Vanguard yet. Fidelity will NOT cancel and then reissue the check in order to make it payable to a Traditional IRA because the error wasn’t their mistake. 

Is there any recourse for this to avoid having it treated as a Roth conversion rollover? The check was issued only 2 weeks ago and hasn’t been sent to Vanguard or deposited anywhere so it seems there must be a way to remedy this.



Maybe have a tax attorney pressure FIdelity to change their mind and return the check with the letter. It’s alot cheaper than 20k PLR which may not be successful. Or litigate against the CPA who should have E&O coverage, probably with a high deductible. 
We are seeing a flurry of these types of situations this year, I don’t know why. Lots of cases where errors of execution are being made or errors of judgment, but with no actual template to correct most of them.  Anything involving the IRS directly such as PLR could easily take 2 years to resolve given their work backlog.

The IRS is accepting ruling requests by fax, and the people working on them are working from home.  The time frame is about 6 months.
However, both a favorable ruling and a successful claim against the accountant are uncertain.
If the original poster wants, I can give him/her a referral to the person I think is best qualified to deal with Fidelity.  Success there isn’t certain, but it’s probably worth trying that first.

Many thanks for these answers and insight. Currently working on an effort to see if Fidelity confirmed individual had read the special tax notice, and if they did not (as would be verfied on the recorded call) then they will reissue the check. Also considering an option where Vanguard (the receiving custodian) rejects the check, also forcing Fidelity to reissue the check. Ultimately it may take a tax attorney if these don’t work.

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