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I have a similar situation where I have exceeded the income level for 2019. I did a Rollover IRA conversion to a Roth IRA with my Fidelity account. I cannot do a re-characterization per the change in the tax law. If I roll all of the money from the ROTH IRA back into the Rollover IRA will that negate the excess contribution penalty? Because it was a rollover it was my understanding that it was not considered an early withdrawal as I am not 59 1/2.