A corrective distribution from a DB plan for many years of missed installment and 401(a)(9) distributions. The total distribution is comprised of $25,000 in principal and an additional $10,000 of income for "loss of use" for a total of $35,000.

The $10,000 portion of the distribution would seem to eligible for rollover based on Q-6 of the 1.402©-2 Q&A as it could be treated as an "independent payment". It's too large to be considered a supplemental payment however would it be reasonable to consider it under the "Administrative error or delay" exemption and not consider it rollable? The example seems to imply a delay due to administrative processing, not a case where the participant was not correctly placed in pay status.

I can argue this one either way. If I were receiving the payment, I'd roll it and fight with the IRS if they challenged, but it is easier to call it non-rollable for administrative purposes. Anyone have an opinion or better yet a PLR that addresses this?