If you want to show the financial planner the statute, it's section 408A(d)(6)(B)(i):
<a rel="nofollow" target="_blank" href="
https://www.law.cornell.edu/uscode/text/26/408A#d_6_B">https://www.law.cornell.edu/uscode/text/26/40...>
You can also see CFR 1.408-11 for the details of the calculation of the gains attributable to the amount being recharacterized: <a rel="nofollow" target="_blank" href="
https://www.law.cornell.edu/cfr/text/26/1.408-11">https://www.law.cornell.edu/cfr/text/26/1.408-11</...>
