I have no idea why a CPA would not understand that money is just money. It's quite reasonable to obtain a loan to get the money to complete the rollover of an offset distribution. It just so happens that you are proposing getting the new loan from your new 401(k) plan rather than obtaining a loan from some other source. Once you have the cash in your hand you can do with it what you want, including using it to fund the rollover of the offset distribution.
