Roth 401k to Roth IRA when unsure of 401k basis

Young client (not yet 59 1/2) has an existing Roth IRA totaling $7,500 that was originally funded back in 2014. She rolled over her Roth 401k assets totaling $70k into the Roth IRA approximately 2 years ago, and now needs a distribution totaling $20k.
We would like to clarify how to assess potential tax/penalty implications if the client is unable to locate her 1099R that would show her the amount contributed to her Roth 401k, since this is not a qualified withdrawal and we cannot be certain how much of the distribution is basis?
Any guidance is appreciated! Thank you!



Client needs to secure a copy of the 1099R to determine the amount in Box 5, which adds to Roth IRA regular contribution basis, which is also needed to report a Roth IRA distribution on Form 8606, line 22. An IRS transcript may be needed if the employer cannot provide a copy. If client has their W-2 for the years Roth 401k contributions were made, those annual amounts are stated on those W-2 forms as well, but the 1099R would provide the total basis. 

If the rollover from the Roth 401(k) to the Roth IRA occurred in 2019, 2020 or 2021, the Form 1099-R should be present in client’s Wage & Income transcript available online from the IRS.  If the rollover happend before 2019, filing Form 4506-T would be necessary to obtain the corresponding transcript.

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