Under the Roth IRA distribution ordering rules, after distributing the $51 of contribution basis, the next $103 comes first from the taxable portion of the rollover from the 401(k), making that portion subject to the 10% early-distribution penalty. Only if less than $103 of the rollover had been taxable would any of the distribution from the Roth IRA have come from basis in the nontaxable portion of the rollover.
