Because no 2024 tax return or request for extension was filed by April 15, 2025, the deadline to obtain a return of contribution before the due date of the tax return was April 15, 2025, not October 15, 2025. This means that the distribution obtained in July 2025 does not qualify for treatment as a return of contribution before this deadline and instead constitutes an ordinary Roth IRA distribution, despite how the financial institution will report it on the 2025 Form 1099-R. (The financial institution will have assumed that it would qualify as a return of contribution before the due date of the 2024 tax return and will code it as such.) As a result, the $3,000 excess contribution is reportable on Part IV of a 2024 Form 5329 and a 6%, $180 excess-contribution penalty paid for 2024.
The $3,800 distribution will need to be reported on your 2025 tax return as an ordinary Roth IRA distribution by entering into 2025 TurboTax as substitute Form 1099-R in place of the code JP 2025 Form 1099-R that you will receive near then end of January 2026. As an ordinary distribution, the $3,800 will be nontaxable either as a qualified distribution or as a distribution of contribution basis, depending on your age at the time of the distribution. Your 2025 tax return will show on Part IV of Form 5329 the $3,00 excess being eliminated by the $3,800 distribution. Filing a substitute Form 1099-R means that you will need to file your 2025 tax return on paper.
