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"Since this is setup, she could roll each of the six accounts over for once a year."
Not since 2014. That's not how the regulations are written. Did you review the links I gave? We all need refreshers, and the regulations change.
This is why I provided Links.
"Beginning in 2015, you can make only one rollover from an IRA to another (or the same) IRA in any 12-month period, regardless of the number of IRAs you own (Announcement 2014-15 and Announcement 2014-32). The limit will apply by aggregating all of an individual’s IRAs, including SEP and SIMPLE IRAs as well as traditional and Roth IRAs, effectively treating them as one IRA for purposes of the limit.
- Trustee-to-trustee transfers between IRAs are not limited
- Rollovers from traditional to Roth IRAs ("conversions") are not limited"
"Background of the one-per-year rule
Under the basic rollover rule, you don’t have to include in your gross income any amount distributed to you from an IRA if you deposit the amount into another eligible plan (including an IRA) within 60 days (Internal Revenue Code Section 408(d)(3)); also see FAQs: Waivers of the 60-Day Rollover Requirement). Internal Revenue Code Section 408(d)(3)(B) limits taxpayers to one IRA-to-IRA rollover in any 12-month period. Proposed Treasury Regulation Section 1.408-4(b)(4)(ii), published in 1981, and IRS Publication 590-A, Contributions to Individual Retirement Arrangements (IRAs) interpreted this limitation as applying on an IRA-by-IRA basis, meaning a rollover from one IRA to another would not affect a rollover involving other IRAs of the same individual. However, the Tax Court held in 2014 that you can’t make a non-taxable rollover from one IRA to another if you have already made a rollover from any of your IRAs in the preceding 1-year period (Bobrow v. Commissioner, T.C. Memo. 2014-21)."
You stated the taxpayer did this themselves, not Trustee-to-Trustee: "money was disbursed but rolled over within 60 day limit."
"Direct transfers of IRA money are not limited
This change won’t affect your ability to transfer funds from one IRA trustee directly to another, because this type of transfer isn’t a rollover (Revenue Ruling 78-406, 1978-2 C.B. 157). The one-rollover-per-year rule of Internal Revenue Code Section 408(d)(3)(B) applies only to rollovers."
You need to Read what the IRS provides.
Also, you stated IRA; not that an employer plan was involved in any direction.
"A warning on multiple IRA rollovers
Tax Court: "Once a year" rollover rule applies to all of a taxpayer's individual retirement accounts."
"In a game-changing decision that has wide-ranging ramifications for financial advisers and tax professionals alike, the Tax Court ruled that the once-a-year IRA rollover rule applies to all of one’s individual retirement accounts, not to each separately (Alvan L. Bobrow, et ux., v. Commissioner, TC Memo 2014-21, Docket No. 7022-11, Jan. 28)."
From:
https://www.investmentnews.com/a-warning-on-multiple-ira-rollovers-56909
"Violating the once-a-year rule can make distributions taxable and, if moved into another retirement account, subject to the 6% penalty for excess contributions."
Now your taxpayer has a need for corrective distributions and has excess funds in the IRA accounts, taking into consideration that the First one would qualify, and don't overlook the CARES Act provisions, to see how much of this damage you can mitigate.
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