Yes, if you want to avoid having to amend your 2020 return because you have to wait for the 1099-R then you can create the 1099-R while filing your 2020 return.
No, it won’t be misleading for the IRS because the 1099-R that you create and will get in 2022 will have the code P and J. The code P indicates that it has to go on the previous year return. Therefore, a 1099-R 2021 with code P will have to go on the 2020 return.
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