Documenting IRA rollover

I am helping my father navigate his taxes the year after my mother has died. My mother had two IRA’s–a traditional and a Roth–that were rolled over to his IRA accounts.

His tax preparer initially mishandled the rollovers, treating them as taxable distributions. We’ve talked with his financial institution and are confident this is not correct, but I am trying (and failing!) to sort out how the tax preparer should be handling this going forward.

We have my father’s account statements documenting that the funds were deposited in his accounts, but it’s unclear to me how to handle this on the actual tax forms. From my internet reading and talking informally with some CPA’s (through my sister, so I don’t have direct access to them), my understanding is that the rollover needs to be reported but is not taxable. However, I’m not sure how this should appear on the tax forms themselves. That is, how does one report the rollover amounts and document that they are not taxable?



Sounds like these were done via 60 day rollovers generating 1099R forms, instead of using recommended non reportable direct transfers from the inherited IRAs. That may have resulted in a problem more serious than just reporting the rollovers, which is exceeding the one allowed 60 day rollover in a 12 month period. Otherwise, his return would simply report a distribution and rollover on lines 4a and 4b of Form 1040. DId he get a 1099R for both the inherited TIRA and inherited Roth accounts? 

Yes, he got a 1099 for both IRA’s.  For the traditional IRA, it was coded 4; for the Roth, it was coded Q. On both, “taxable income not determined” was checked.  My sister, who worked with the financial institution (with my father) to do the rollovers, thought it was a direct rollover.Are you saying that if it was a direct rollover, we should not have gotten a 1099 at all?

  • Yes, that is correct except that the correct term is a direct transfer. A direct transfer does not generate a 1099R nor a corresponding 5498 from the receiving custodian, and is not considered a rollover. 
  • The rollover contribution that was done first is the allowed rollover, the other is not allowed and would be taxable if the second one was the traditional IRA. This is unfortunate, and the custodian (if the same for both accounts) should have warned your sister about this well known limit.
  • The correction would be that the second would should not be reported as a rollover, and the contribution of that second one treated as an excess regular contribution to the applicable IRA and removed as adjusted for gain or loss.
  • There might also be RMD issues to contend with since these were distributions. Was Mom subject to RMDs, and if so had she completed her RMD for the traditional IRA for the year of death?  If not, a portion of the traditional contribution would be considered as the RMD.
  • Can be more specific with additional info such as dates and amounts and if Mom was subject to RMDs. 

I’m confused about transfer vs. rollover. This IRS site mentions transfers, direct rollovers, and 60-day rollovers. It seems you are saying that there should be no 1099 for a direct transfer.  But does the same apply to a direct rollover?  Is it possible that my father had a direct rollover rather than a direct transfer? Regarding the RMD: My mother died at the very end of 2021. My understanding is that the IRA was transferred early in 2022 and the RMD was issued entirely from my father’s IRA, to him.

I was able to pull up the account records for my father’s IRAs. In those records, it lists a transfer/adjustment from my mother’s accounts into my father’s accounts. (From my naive reading, it seems that it was a direct transfer; so I don’t really understand why we got the 1099.) I did check that the transfer for the traditional IRA happened the day before the transfer for the Roth IRA. In this case, it sounds like you are saying that the traditional IRA would be the acceptable rollover and would then be not taxable income.

 

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