No 1099-R Provided

[manderson3]

I made a 401k to Roth 401k conversion on December 31, 2019. My provider is refusing to provide a 2019 1099-R, stating that the cutoff for 2019 was December 30. I planned my taxes around the conversion occurring in 2019. Can I claim the income in 2019 without the 1099-R form?

[JulieS]

No, that is not a good idea. If you can't get the provider to issue the 1099-R for 2019, you are certain to get a letter about not reporting it in 2020.

Did the conversion actually take place in 2019, or did they process it in 2020 even though you arranged it in 2019?

If the actual conversion took place on December 31, 2019, they are supposed to issue the 1099-R for 2019. They may have taken your order for the conversion and processed it after January 1, 2020. 

You can try again to get your 1099-R issued in 2019, but they won't do it, you should report the conversion in 2020.

[macuser_22]

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@manderson3 wrote:

I made a 401k to Roth 401k conversion on December 31, 2019. My provider is refusing to provide a 2019 1099-R, stating that the cutoff for 2019 was December 30. I planned my taxes around the conversion occurring in 2019. Can I claim the income in 2019 without the 1099-R form?

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That is the pitfall of waiting to the end of the year.   Most (if not all) financial institution specify in the account agreement, that transactions will take 2-3 business days to post.  If the transaction date and posting date spans calendar years, then the transaction is deemed to have occurred in the following calendar year.

The account trustee will report this to the IRS as a 2020 transaction and issue a 2020 1099-R in Jan 2021 to go on your 2020 tax return.

Always allow 2-3 business days for the transaction to post when making time dependent transactions.   The IRS goes with what is reported by the financial institution.

[manderson3]

I understand that sometimes things take time to process, but my account shows the transfer occurred on the 31st. Since the transaction took place in 2019 I think the income should be included in 2019 as well.

The flip side of this is a charitable transaction. If a charitable transaction occurs on 12/31/19 it cannot be moved to 2020, correct? 

[macuser_22]

You would have to convince the financial institution that issued the 1099-R to change it.   Read the account agreement (including the fine print).

Some agreements specifically state what happens on Dec 31 (New Year's Eve) and what year it will be posted for.

[manderson3]

My account shows that the transaction occurred in 2019, which is why I am frustrated that they are not providing a 1099-R for it. Am I legally entitled to it? 

[macuser_22]

You are legally entitled to what the account agreement says that you are entitled to.

Read the account agreement (including the fine print).

We cannot give legal advice.  If you think you have a legal case then consult your own attorney for legal advice.

What the financial institution did is standard industrial procedure and happens all the time.  That is why I always advise people that must take RMD's (Required Minimum Distribution) at age 70 1/2 to NEVER leave it to the end of the year or it  probably will not get posted until the following year and that becomes a missed RMD that is not easy to fix.