@dmertz Just so that I understand this, there appears to be a subtle distinction between direct "transfers" from IRA to IRA and from qualified plan (401k) to IRA. IRC 402(c)(1)(B) calls such transfers distribution. But the 1099-R instructions ("Direct Rollovers") define that in terms of where the money is coming from and say nothing about reporting IRA to IRA trustee transfers. Do you have better citations saying that IRA to IRA TTEE transfer is not a rollover and isn't reported on a 1099-R?
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