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I helped a friend through a recharacterization of a Roth IRA over-contribution made in 2018 (with most excellent advice from folks on this board). In that case, she recharacterized during 2019 (before filing 2018 taxes), so the 1099-R arrived in early 2020 as a 2019 distribution. She filed an 8606 with her 2018 Form 1040, since the excess Roth contribution was made in that year and recharacterized to a non-deductible traditional IRA contribution for that year. An explanatory note was included to say the 8606 was included for 2018, but the 1099-R for this would be shown as a 2019 distribution, and appear on the 2019 return. The 2019 1099-R showing that non-deductible contribution (including net income attributable) was entered into the 2019 Form 1040, showing the total distribution, but with $0 taxable. All as expected.

For 2019, for various reasons, someone else did her taxes. She also had a Roth IRA excess contribution for 2019 ($1,500 made before realizing they would be "excess"), and proceeded to recharacterize the total amount in early 2020. She now has a 2020 Form 1099-R for the non-deductible IRA contribution ($1,500 + net income attributable distribution, with $0 taxable). But .. no 8606 was filed for 2019.

So, how to proceed to make sure the appropriate 8606 is on file and the complete history is there for future use when withdrawing from the traditional IRA many years in the future?

1. Probably wrong, but can she simply file an 8606 as part of her 2020 return, showing $1,500 as the non-deductible contribution? I say probably wrong because line 1 of the 8606 for 2020 says: "Enter your nondeductible contributions to traditional IRAs for 2020, including those made for 2020 from January 1, 2021, through April 15, 2021". The years aren't quite right. :-)

2. Can she simply send in a Form 8606 for the 2019 tax year (where the years are correct), with an explanatory note saying it was omitted from the initial filing? The note would also include words similar to "this is for 2019, although the 1099-R will be issued for 2020 and show up in the 2020 return".

3. Does this 8606 have to be filed as part of an amended 1040-X?

4. Or something else?

Thoughts/guidance appreciated. As always, thank your for any help!

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