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Thanks for answering, RooCat.

The net income earned by the contribution is included in income ...

I understand that. I'm wondering if I can characterize it as long-term capital gains, if I wait long enough to take the distribution. Since the distribution is reversing the effect of the the excess contribution, it's as though the money was never in the Roth. Seems reasonable to me. On the other hand, distributions from a Roth are taxed as ordinary income, at least as a general rule.

Does the IRS offer any clarity on this point?

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