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about a year or two ago the IRS ruled that yes, it is.
Seems kinda crappy as the adjustment in basis means nothing in the Roth because there is no Capital Gains tax consideration.

True, but there's logic to the rule, as well. You owned 100sh. of XYZ Corp a month ago. Today you still do, but now it's in the IRA - or Roth, either way. You just flipped shares between accounts, and didn't actually, finally, realize a loss. And that's what the rule is designed to prevent.

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