If you have another IRA, you could potentially move enough funds back to the closed IRA account by trustee-to-trustee transfer to cover the UBIT. If you have no other IRA, you might be able to roll the necessary amount from the 401(k) back into the IRA, plan permitting. Regardless, this is an amount that should not have been rolled over to the 401(k), so it needs to be removed from the 401(k).