Clarifying CARES Act 401k withdrawal questions from 2020
I pulled $40k from my 401k under the CARES Act back in 2020 when my wife's manufacturing job kept shutting down due to COVID outbreaks. I just realized my 2020 1099-R shows distribution code 1, which I think means it wasn't properly coded as a CARES Act withdrawal? Only noticing this two years later. The form shows: Box 1 and 2a: $40,000 Box 4 Fed tax withheld: $4,000 Box 14 State tax withheld (NJ): $1,350 Everything else is zeroed out. I've heard trying to get this fixed now might trigger IRS attention. I haven't done anything sketchy with taxes (not smart enough for that lol), but dealing with the IRS sounds like a nightmare. I haven't gotten a 1099-R for 2021 yet - should I have received one by now? Is it worth trying to get the distribution code changed? How do I handle paying the remaining taxes, and do I even owe more since they already withheld $4k? Looking at my 2020 tax packet, line 5a (Pensions & Annuities) shows $40,000 and 5b (taxable amount) shows $13,333, so I think they taxed me for 1/3 of it that year. I'm completely confused about what to do next. Any advice appreciated!
18 comments


Noah huntAce420
The distribution code 1 on your 1099-R indicates a normal early distribution, not a CARES Act withdrawal which would typically show code 2 with additional notes or a separate form. This coding issue is actually quite common during that period as many plan administrators were slow to implement the proper codes. Looking at your tax return details, it appears your tax preparer or software did properly treat it as a CARES Act distribution despite the incorrect code. The fact that only 1/3 ($13,333) was reported as taxable in 2020 confirms this, as that's exactly how CARES Act withdrawals were supposed to be reported - spread equally over three tax years unless you elected otherwise. You should have received 1099-Rs for 2021 and 2022 only if you made additional withdrawals. The CARES Act taxation happens automatically across the three tax years regardless of whether you receive additional forms.
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Ana Rusula
•Wait, so if the tax return shows they only taxed 1/3 of it that first year, does that mean the other 2/3 gets taxed automatically in 2021 and 2022? Or was I supposed to manually report something? I didn't withdraw anything else from my 401k after that initial $40k.
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Noah huntAce420
•Yes, if your 2020 return reported only 1/3 of the distribution as taxable, then the IRS system automatically includes the other 1/3 portions in your 2021 and 2022 tax years. You don't need additional 1099-Rs for those years. When you prepare your taxes for 2021 and 2022, you need to manually report the additional 1/3 portions ($13,333 each year) as income on your tax return. The tax software should have a specific input area for "CARES Act distribution from previous year" or something similar. If it doesn't prompt you, you may need to enter it as "Other Income" with a description.
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Fidel Carson
After dealing with similar CARES Act confusion last year, I want to recommend using https://taxr.ai to review your tax documents. I was also confused by distribution codes on my 1099-R and wasn't sure if my retirement withdrawal was processed correctly. I uploaded my tax forms to their system and got a detailed explanation of how my CARES Act distribution was handled and what I needed to report each year. They also identified that my plan administrator had used the wrong code but my tax software had handled it correctly.
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Isaiah Sanders
•Does this actually work for complicated situations? I had a CARES Act withdrawal but also did a rollover in the same year and my tax person completely messed it up. Would this service be able to figure that out?
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Xan Dae
•I'm suspicious of any service that claims to interpret tax documents. How do they handle security concerns? I wouldn't want to upload sensitive financial information to some random website.
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Fidel Carson
•For complicated situations like rollover plus CARES Act withdrawal, it worked really well for me. The system recognized both transactions separately and explained how each should be handled. It even flagged that my tax preparer had missed reporting a portion of the CARES distribution in year two. Regarding security, they use bank-level encryption and don't store your documents after analysis. They explained their whole security process before I uploaded anything, which made me comfortable. I was hesitant too at first but it saved me from making a costly mistake on my taxes.
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Isaiah Sanders
Just wanted to follow up - I tried the taxr.ai service that was recommended here and it was super helpful! I uploaded my confusing 401k documents and it immediately identified that my rollover had been incorrectly coded on my taxes. The analysis showed exactly what I should have reported vs what was actually filed. Now I'm getting an amendment ready before the IRS comes knocking. Wish I'd found this earlier instead of trusting my tax guy who clearly didn't understand CARES Act rules.
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Fiona Gallagher
If you're still confused about your CARES Act withdrawal after getting advice, I'd recommend using Claimyr (https://claimyr.com) to actually speak with an IRS agent directly. I was in a similar situation with incorrectly coded retirement distributions and spent weeks trying to get through to the IRS with no luck. Claimyr got me connected to an actual IRS representative in about 15 minutes. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c. The agent I spoke with confirmed exactly how to handle the remaining years of my CARES Act distribution and noted it in my account.
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Thais Soares
•How exactly does this work? Isn't it just the same as calling the IRS directly? Why would I need a service for that?
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Xan Dae
•Yeah right. There's no way anyone is getting through to the IRS in 15 minutes. I've spent HOURS on hold only to be disconnected. This sounds like a scam where they just take your money and you still end up waiting forever.
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Fiona Gallagher
•It works by constantly redialing the IRS using their system until they get through, then they call you and connect you directly to the IRS agent. It saves you from having to sit on hold for hours. The service is definitely different from calling directly. The IRS phone system is notorious for long wait times or just disconnecting you entirely. Claimyr's system automatically navigates the phone tree and waits on hold for you, then calls you when an actual agent is on the line.
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Xan Dae
I have to admit I was completely wrong about Claimyr. After commenting here, I decided to try it because I was desperate to resolve my own CARES Act issue. I got connected to an IRS representative in about 20 minutes, which is honestly miraculous compared to my previous attempts. The agent confirmed that despite my 1099-R having the wrong code, the system had properly registered my withdrawal as a CARES Act distribution. They also explained exactly how to report the remaining portions on my 2021 and 2022 returns. Seriously saved me weeks of stress and uncertainty.
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Nalani Liu
Another thing to consider - if you're having financial difficulties, you can actually elect to report the entire CARES Act distribution in the first year rather than spreading it over three years. This might be beneficial if you had a particularly low income in 2020 compared to later years. You'd pay all the tax at once, but potentially at a lower rate.
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Axel Bourke
•Can you still make that election now? Or was that something that had to be done on the 2020 return?
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Nalani Liu
•Unfortunately, the election to report the full amount in the first year had to be made on your original 2020 tax return. Since you already reported only 1/3 of the distribution as taxable in 2020, you're now locked into the three-year reporting method. The only way to change this would be to file an amended 2020 return (Form 1040-X), but that has risks and costs that likely outweigh any potential benefits at this point. You'd pay interest and possibly penalties on any additional tax from reporting the full amount in 2020, plus you'd draw additional scrutiny to your return.
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Aidan Percy
Has anyone dealt with repaying a CARES Act withdrawal? I took money out in 2020 but now I'm in a better position and wondering if I should put it back to avoid the taxes for 2021 and 2022.
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Fernanda Marquez
•You can repay a CARES Act distribution within 3 years of the date you received it to avoid taxes on the repaid amount. So if you took it out in July 2020, you have until July 2023 to put it back. You'll need to file amended returns to get back any taxes you already paid on the portions reported in 2020 and 2021.
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