Then the client should have taken 2 distributions.  It all gets reported in the year received.

Client 'wants' isn't part of the IRC.

Wow, where did your taxpayer get that idea? This is the only provision, in the past, and it was conversions, not distributions.

"However, under the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA) these previously ineligible taxpayers will be eligible to participate starting this year (including married but separate filers). In fact, there is an incentive to take action in 2010: Everyone who converts this year may defer and spread income recognition from the conversion over tax years 2011 and 2012."

From: https://www.journalofaccountancy.com/issues/2010/jan/20091743.html