IRA Withdrawal/60 Day Rollover

Hi, I have a rather complicated question. I purchased a home in march and withdrew $40K from my IRA for a down. I was able to roll it back over within 60 days. As the end of the year approaches, I’m reconsidering whether I should have held onto the $10K penalty free exception for first time home buyers. My question is, if I take another $10K out now, since I technically did take $40K out initially for the home purchase qualifying for the 20 days expenditure from date of withdrawal, will the IRS consider my net $10K annual withdrawal as subject to income tax only and not an early withdrawal penalty or did I miss the boat in rolling it all over within 60 days and not holding on to the $10K at that time? Thanks for your input.



Do you still have qualified acquisition costs that have not yet been paid, or would this distribution be for reimbursement of such costs that have already been paid? Note that even if the penalty exception applies you would still owe ordinary taxes on the distribution, you would use up the lifetime exception, and you could not change  your mind and roll it back.

This would be to reimburse costs I legitimately paid with the first withdrawal, I though that I was in good shape on redepositing the funds but as taxes and other home costs pile up I realize I should have kept the first time homebuyer $10k exception to early withdrawal penalty. I do realize I will still pay income tax, just wondering if the net withdrawal is $10 will I still not face a penalty despite redepositing it and taking a withdrawal now, after the costs were paid with funds which were redeposited as a rollover. 

I cannot locate anything on point regarding reimbursement of previously paid acquisition costs. Appears to be a gray area. If you want to avoid the gray area and have a Roth IRA, you could take a Roth distribution of 10k which would probably be non taxable and derived from your regular Roth contributions. You could then convert 10k from your TIRA to your Roth IRA and pay tax but no penalty. Of course, if you did that the composition of your Roth IRA from that point on would not be as favorable if you needed to take additional Roth distributions before your Roth was qualified.

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