No 1099-R?

[Janitor Bob]

I have prepared returns for a couple for several years....they have 3 documents every year:  His SSA-1099, her SSA-1099, and her 1099-R (which is the only reason they need to file returns at all and is the source of their refunds due to Fed and OH tax withheld).  This year, no 1099-R.  I checked and the 2015 1099-R did not have a box checked for total distribution.  I tell client that I am missing the 1099-R.  She tells me that there isn't one because she moved all of that money to a different bank.  I try to explain that the original bank would have still issues a 1099-R just possibly coded G for rollover.  She disagrees saying "I used to get money every month, but didn't get any money in 2016 because I moved it...so I won't get a 1099".  I suggets she call the original bank (JPMorgan Chase) and provide her with the phone number and account # from the 2015 1099-R.

She tells me she called them and they confirmed no 1099-R. ????  Am I missing something here?

[Lion EA]

New bank didn't do RMD?  Is she old enough that it's required?  Have her call new bank.  Curious!

[Janitor Bob]

No RMDs yet...not until next year...she told me she called both banks and both told her no 1099-R....I just don't get it

I give up...I told her that based on her information, no 1099-R means they do not even need to file (in fact, I do not even think ATX will let you e-file a return with all zeros).....and told her not to be surprised if she gets a letter from IRS eventually on this subject.

[Lion EA]

If she doesn't require RMDs yet and doesn't need the distribution and didn't take any distributions, then no 1099-R.  Her choice to let it grow more until RMDs are required.

If they don't file, the SOL never runs.  Especially this year when you're suspicious that there might be income out there, urge them to file so if something shows up, at least they won't have a failure to file penalty.

If you're suspicious, you could do a quick income vs. expenses calculation to see if they are living on only SS.

[jasdlm]

Hi, JB.  I had a similar issue this year.  Turned out that Wells Fargo did NOT do a 1099R because they considered it a 'transfer' to the other company and not a rollover.  Feels weird, but I sent it through.

[FDNY]

If assets are moved from qualified plan to qualified plan and employer sponsor is the same no 1099R is required.  Same as transfer from IRA to IRA or Roth to Roth, etc.   Yes, it sounds weird, but that's all I got.   But when you think about it,  it probably saves a tree or two, so that's a good reason.

[Jack from Ohio]

12 minutes ago, Janitor Bob said:

No RMDs yet...not until next year...she told me she called both banks and both told her no 1099-R....I just don't get it

I give up...I told her that based on her information, no 1099-R means they do not even need to file (in fact, I do not even think ATX will let you e-file a return with all zeros).....and told her not to be surprised if she gets a letter from IRS eventually on this subject.

You did right.  You can lead a horse to water....

 

[Roberts]

3 hours ago, Lion EA said:

If she doesn't  RMDs yet and doesn't need the distribution and didn't take any distributions, then no 1099-R.  Her choice to let it grow more until RMDs are required.

 

This, not seeing that a 1099r is absolutely required. They aren't going to produce one if a distribution isn't made and if she isn't applicable to RMDs, you can't make the leap that a 1099r is absolutely required.