Client took two distributions from two separate retirement accounts for 100K each back in June of 2020. I informed him only the first 100K is eligible for the 3 year averaging and no 10% penalty. Can he deposit the second 100K back into his account before we file his return, would this be considered a recontribution or is that for only one distribution.
It isn't "recontribution." It's Rollover. The three-year Rollover provision was extended for covid distributions. Your taxpayer, for their Second distribution, was supposed to follow the 60-day rule.
That includes the waiver provision. I would think the covid rules were confusing enough to typical taxpayers that this would be granted. You won't know if you don't try.
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