If we convert funds from a 529 to a Roth IRA, are those funds considered new contributions and are they therefore accessible without taxes or penalty. For example a client of ours converted $13,500 from 529 to ROTH IRA  $6k for 2023 and $6500 for 2024. Can he now withdraw that $13,500 out tax and penalty free for any purpose as if it were new contribution?