My understanding of the IRS rules for “More than one distribution” (for example, from Page 26 of Form 1040 instructions for 2019) is that the total amount of all distributions, whether from RMDs or Roth conversions should be recorded on Line 4a (for 2019 in this example) and the taxable portions of those distributions should be reported on Line 4b (again, for 2019 in this example).

For a married couple (aged 74+, in retirement) filing jointly, let’s assume:

– Individual 1 has a RMD of $3000 from the traditional IRA
– Individual 1 converts another $30000 to Roth IRA from the traditional IRA
– Individual 2 has no RMD (the traditional IRA is already empty)
– Individual 2 has no conversion to Roth IRA (again, because the traditional IRA is already empty)

For, for reporting purposes, Individual 2 has no bearing on what is reported on Lines 4a and 4b (it will all be based on Individual 1). So it seems as if Line 4a should be $33000, and Line 4b should be $33000 as well.

But because $30000 of that was from a Roth conversion, a Form 8606 would be required as well. Part 2 of Form 8606 for 2019 would include $30000 on Line 16 and Line 18, assuming no nondeductible contributions were involved.

But let’s say an error was made and all $33000 was reported on Lines 16 and 18 of Form 8606 (while Lines 4a and 4b of Form 1040 remain unchanged). In reality, the statements and 1099-R forms and 5498 forms for all the accounts involved can substantiate what was distributed and converted, etc., if asked. And the full taxable amount on Form 1040 ($33000) was indeed reported, so the IRS didn’t get shorted.

But, will the IRS now expect to see an additional $3000 conversion somewhere in the paperwork between the accounts? Does an amendment or some other explanation need to be filed now to explain the discrepancy?