Best way to respond to IRS CP2000 notice for IRA distributions?
I'm facing a difficult situation with a CP2000 notice from the IRS regarding IRA distributions from 2021. My husband and I received this notice because we failed to properly report distributions totaling about $52k (roughly $19k from Traditional IRA and $33k from Roth IRA). We had withdrawn the money with plans to purchase our first home, but our closing got delayed and we didn't complete the purchase until March 2022 - outside the 120-day window for the first-time homebuyer exception. The Traditional IRA was from a 401k rollover with $0 basis, so I understand we'll owe taxes and the 10% penalty on that portion. The Roth distribution was almost exactly the amount I contributed (my basis), so I believe that part should be tax-free. What complicates things is that I've been dealing with some serious health issues that have affected my cognitive abilities. I used to work in finance and thought I understood the tax implications, but my medical condition has made it hard for me to process complex information. I'm now on disability because of it. I've completed Form 8606 showing the correct basis information for both IRAs. Should I send this form along with a letter explaining the situation? What's the best approach to respond to the CP2000 and minimize any penalties? I want to address this correctly.
18 comments


Isaiah Thompson
The best approach is to respond to the CP2000 with a clear explanation and supporting documentation. Since you've already completed Form 8606 showing your basis in the IRAs, that's an excellent start. Here's what I recommend including in your response: 1. A brief, factual explanation of what happened (no need to overexplain your medical situation - just focus on the tax facts) 2. The completed Form 8606 showing your basis in the Roth IRA 3. A statement acknowledging that you understand the Traditional IRA distribution is fully taxable with the 10% penalty 4. A statement clarifying that the Roth distribution was a return of contributions (basis) and therefore not taxable For the Roth portion, the IRS needs to see that you're only withdrawing what you put in (your basis), which makes it non-taxable. For the Traditional IRA, you'll unfortunately need to pay the taxes and penalty. Don't ignore the notice or delay your response - CP2000 notices have a deadline, and failing to respond could lead to automatic assessment of the full proposed amount.
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Ruby Garcia
•Thanks for the detailed response. Would it help to include any documentation from the brokerage showing the original Roth contributions that establish the basis? Also, are there any options for getting the 10% penalty waived on the Traditional IRA portion given the medical circumstances?
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Isaiah Thompson
•Including documentation from your brokerage showing the original Roth contributions would absolutely help strengthen your case. The more evidence you can provide to substantiate your basis claim, the better. Regarding the 10% penalty on the Traditional IRA withdrawal, there are limited exceptions to this penalty. Medical hardship can qualify, but it's specifically for unreimbursed medical expenses that exceed 7.5% of your adjusted gross income. The disability exception typically applies if you're totally and permanently disabled when taking the distribution. Since you were not on disability at the time of the withdrawal but rather became disabled later, this exception likely wouldn't apply retroactively to your 2021 distribution.
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Alexander Evans
I went through something similar with a CP2000 notice for unreported IRA distributions. I spent hours trying to explain my situation to different IRS representatives with little progress. Then I found https://taxr.ai which analyzes your tax documents and helps you draft the perfect response to IRS notices. Their system specifically asks about IRA distributions and basis amounts and walks you through exactly what forms and documentation you need to include with your response. It helped me identify that I needed my Form 5498s (which show IRA contributions) for all applicable years to prove my basis. The best part was they helped me craft a response letter that addressed all the technical points without getting bogged down in unnecessary details. My case was resolved quickly after submitting their recommended response.
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Evelyn Martinez
•Did you have to submit through mail or could you handle everything electronically? I hate dealing with paper forms and waiting weeks for mail delivery.
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Benjamin Carter
•Sounds like another paid service pushing their product. How much does it cost and is it really worth it when you can just call the IRS directly and explain?
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Alexander Evans
•You have to submit your CP2000 response through whatever method the notice indicates - for me it was mail, but some newer notices allow electronic responses. The tool helps prepare everything, but you handle the actual submission based on the IRS instructions. The service isn't expensive compared to hiring a tax professional for something like this, and definitely worth it in my situation. You can absolutely call the IRS directly, but in my experience, representatives often give inconsistent information about complex situations like IRA basis calculations. Having documentation properly prepared before any conversation with the IRS helps tremendously.
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Benjamin Carter
I initially thought those tax document services were a waste of money, but I tried https://taxr.ai after getting frustrated with my CP2000 situation. I had a similar issue with Roth IRA distributions that weren't properly reported on my return. The system helped me organize years of contribution records that I honestly didn't even know I needed to keep. It turns out I had been making after-tax contributions to my Traditional IRA that I never properly tracked on Form 8606, so I was at risk of paying taxes twice. I'm normally pretty skeptical about these services, but it saved me thousands in incorrect tax assessments. The IRS accepted my response with all the documentation the system helped me prepare, and they reduced the proposed assessment by over 80%.
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Maya Lewis
After dealing with multiple CP2000 notices over the years (self-employed with complicated taxes), I finally discovered that calling the IRS directly is the fastest way to resolve these issues. However, I spent WEEKS trying to get through their phone system until I found https://claimyr.com - they have a service that actually holds your place in the IRS phone queue and calls you when an agent is about to answer. I used their service when I got a CP2000 for an IRA distribution I didn't properly document. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c Once I finally got through to a real person at the IRS, they were able to look at my account and give me specific instructions on exactly what documentation they needed to resolve my case. Saved me from sending unnecessary paperwork and potentially making the situation worse.
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Isaac Wright
•How does that even work? Don't they ask for all your personal info when you call the IRS? How can a service get through the initial verification process?
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Lucy Taylor
•That sounds sketchy as hell. I wouldn't trust some random service to handle my IRS calls. There's no way this is legitimate - the IRS would never allow a third party to hold places in their phone queue.
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Maya Lewis
•They don't actually talk to the IRS on your behalf. Their system dials into the IRS queue and monitors the hold music and automated messages. When it detects that a representative is about to pick up, it calls you and connects you directly. You handle all the verification yourself - they just save you from sitting on hold for hours. The system just saves you from the endless hold time. You're still the one who talks to the IRS agent and provides all verification information. It's basically like having someone else redial the IRS number over and over for you until they get through.
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Lucy Taylor
I was extremely skeptical about any service claiming to help with IRS calls - it seemed like a scam. But after spending 4+ hours on hold one day only to have the call dropped, I reluctantly tried https://claimyr.com. To my surprise, it actually worked exactly as described. I got a call about 90 minutes after starting the process, and was connected directly to an IRS representative. They hadn't talked to anyone on my behalf - they just held my place in line. The IRS agent walked me through exactly what I needed to submit for my CP2000 response regarding some IRA distributions I had incorrectly reported. Having that direct conversation saved me from making mistakes in my written response that would have dragged the process out even longer.
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Connor Murphy
Make sure you're responding to the CP2000 by the deadline! The most important thing is to not ignore it even if you don't have all your documentation yet. For the Roth IRA portion, you need to prove your basis. The IRS assumes all distributions are earnings unless you can document your contributions. If you don't have records of your contributions, contact your IRA custodian ASAP to get historical statements. For the Traditional IRA, you're right that you'll owe taxes plus the 10% penalty since you didn't qualify for any exceptions. One thing to consider: if paying the total amount would cause financial hardship, you can request a payment plan when you respond to the CP2000. They're usually pretty reasonable about setting up installment agreements.
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Jessica Nguyen
•Thanks for the reminder about responding by the deadline. The due date is in about 3 weeks, so I have a little time. Do you know if I'll get a separate bill for the penalties and interest, or will that be included in what I pay when I agree to the CP2000 assessment?
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Connor Murphy
•When you agree to the CP2000 assessment, the response form will show the total additional tax amount they're proposing. This typically includes the 10% early withdrawal penalty for the Traditional IRA portion, but it does not include interest and potential late payment penalties. Those additional amounts will be calculated and included in the actual bill you receive after you've agreed to the assessment. The IRS will send you a separate notice (usually a CP22A) with the final amount including any interest and penalties. Interest continues to accrue until the amount is paid in full. If you're concerned about the total, it's definitely worth requesting an installment agreement either with your CP2000 response or when you receive the final bill. You can use Form 9465 to request a payment plan.
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KhalilStar
Make sure you're using the correct year's Form 8606! I made the mistake of using the current year form instead of the form for the tax year in question. The IRS rejected my response and it added months to the process. You can find old tax forms on the IRS website by searching for "prior year forms." For 2019 forms (which I think is what you need based on your post), go to this page: https://www.irs.gov/forms-pubs/prior-year
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Amelia Dietrich
•This is such an important point! I did the same thing and it caused all kinds of confusion. The IRS forms change slightly from year to year, and using the wrong one can really mess things up.
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