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Actually there may be precedent to allow this, but it's a bit of a long shot. Back in 2009 when RMDs were last suspended, the IRS issued Notice 2009-82 in October 2009 which extended the 60-day window for RMD distributions that had been made earlier (some plans didn't adopt the new rules quickly enough) in the year up through November 30, 2009.

The CARES Act defines eligible rollover distributions by replacing "2009" with "2020" in IRC section 402(c)(4). It is uncertain whether this change extends to the further modification of Notice 2009-82 or whether this needs to be addressed in a Technical Correction or further IRS action.

Ira
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