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I think aj485 probably understood this was implied.

Actually, no I didn't. Because there wasn't anything mentioned about basis or non-deductible contributions, my initial answer was based on converting a Traditional IRA without any basis, since that's the more typical case.

For an account with basis, as vkg indicated, it used to be if you distributed the entire balance of a Traditional IRA and still had basis that hadn't been used up, the loss would be deducted as a miscellaneous deduction, subject to the 2% of AGI rule. From the 2017 590-B https://www.irs.gov/pub/irs-prior/p590b--2017.pdf

Recognizing Losses on Traditional IRA Investments
If you have a loss on your traditional IRA investment, you can recognize (include) the loss on your income tax return, but only when all the amounts in all your traditional IRA accounts have been distributed to you and the total distributions are less than your unrecovered basis, if any. Your basis is the total amount of the nondeductible contributions in your traditional IRAs. You claim the loss as a miscellaneous itemized deduction, subject to the 2%-of-adjusted-gross-income limit that applies to certain miscellaneous itemized deductions on Schedule A (Form 1040). Any such losses are added back to taxable income for purposes of calculating the alternative minimum tax.


However, the TCJA eliminated miscellaneous deductions, so there is no longer a provision to deduct the loss. That said, I don't know that there was ever any provision to 'carry over' or 'retain' the basis when your account balance is $0. And I'm not sure I would like to be the test case when the IRS argues that an account balance of $0 can't have a basis.

But I'm not aware of anything in the tax code or IRS rulings that explicitly requires you to zero-out the cost basis just because your balance went to $0. So I think my interpretation is correct.

I think that you may very well be incorrect. Given that there was specifically a provision to deduct the loss, I think that the absence of any direction of how to carry over a loss with a $0 account balance means that the IRS hasn't established a way to do so. That's kind of confirmed by the fact that the section on 'Recognizing losses on Traditional IRA Investments' has been removed and not replaced in the 2018 Pub 590-B https://www.irs.gov/pub/irs-pdf/p590b.pdf And as I said, I'm not sure that I would want to be the test case.

If I'm wrong, I'm going to start leaving a $1 in my account just to be sure. In fact I may start doing that anyway.

I would actually suggest leaving more than $1 in the account - probably something closer to the amount of the loss you are trying to preserve, assuming there's at least that much left in your account. If there isn't that much left in your account, I would suggest not doing a conversion that year.

AJ
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