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Bill, if I understand correctly, you are saying that each year from now on this will be consider a rollover by the IRS.  I do not understand the 60-day rule after you receive the distribution, as there is not a distribution.  If you represent Intuit TurboTax and will stand behind the software, then I will send in my amended 2023 taxes.  This has never been an issue with the TT software for the past 5 years, and I do understand changes can be directed by the IRS.  My concern has always been the instructions for line 2 on form 8889 say "HSA contributions you made for 2023."  I will include all of your post with my amended 2023 taxes to the IRS.