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Subject:  1099R for a Transfer? Date:  2/28/2013  12:52 PM
Author:  DWBardy Number:  117899 of 127616

My wife used money that was in a traditional IRA to repay years of service credit she had previously withdrawn from a Teachers' Retirement System (IRC 401A plan - defined benefit plan). This check was addressed to the T.R.S. (FBO my wife) and went DIRECTLY to the T.R.S. so it would seem to be a trustee to trustee transfer, NOT a rollover. Nevertheless, Merrill Lynch chose to issue us a 1099R showing the amount as a distribution and used Code 1 (Early Distribution, no known exception), instead of Code G (Direct rollover and rollover contribution (other than a designated Roth account distribution) to a qualified plan).

My questions:
1. Is this a rollover requiring issuance of a 1099R, or is it a trustee to trustee transfer for which NO reporting is required?
2. If a 1099R is required, was the correct code "1" or should it have been "G"? If "G", will I have any luck getting Merrill Lynch to revise the 1099R?
3. Will the IRS accept my showing -0- as the taxable portion of the distribution if I simply write "Rollover" on the appropriate line?

Any insights would be appreciated!
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