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Any time there are taxes involved with the IRA, you have to pro-rate your "tax basis" (after-tax contributions) based on all Traditional IRAs, so you end up not being able to cherry-pick the Traditional IRA for the tax treatment.

I said that just for simplicity of recordkeeping. It would be easier with regards to paperwork to convert a non-deductible traditional IRA to a Roth IRA if it isn't comingle with a 401k rollover (if in the future you are below the conversion limits).

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