Form 1099R Reported Incorrectly For Years

[taxea]

Why would you advise amending the last 6 years when the SOL is 3 years?

The SOL on 1040's is 10 years, on assessing liability 3 years but if audited and IRS suspects there may be repeating errors they can go back 6 years or all 10.

[JohnH]

So by recommending that they amend "at least 6 years", you are essentially telling your client to audit themselves rather than wait to see if IRS is interested in going back further.
Nice client services there..

[geekgirldany]

I talked to my client yesterday. I recommended 3 years but the IRS could go back 6 years. I want the client to be prepared for 6 years just in case.
She is going to get back to me on amending the tax returns after the tax season.

[JohnH]

I think you gave your client excellent advice.
And your client is also being smart.

[Burke]

This week I received the tax documents for a MFJ client. Husband had been receiving "Office of Personnel Management Retirement Operations" Form CSA-1099R for many years. Employee costs were recovered within the last couple of years, so all has recently been taxable.

Husband died in 2017, and wife is now receiving survivor ("Code 4") benefits. Her CSA-1099R is exactly the same document as that of her late husband, to include "unknown" in Box 2. The "total employee contributions" is the same number on both tax documents, and is the amount used 20+ years ago to determine the annual exclusion for the husband.FE

And that is the way I have always experienced these situations. CSA does not change their 1099-R info. I run into numerous ones on persons who are WAY beyond their full retirement age that still show Code 3 (disability retirement) which is treated as wages prior to normal retirement age; then switches to treatment as a pension which should be a Code 7. In your case, the wife continues her husband's recapture. It does not start over. So if he recovered all contributions in the last few years, hers will be fully taxable now as his was when he died.