attempt to obtain an amended 1099-R which should resolve issue. CP-2000 group is only interested in 1099-R amended. You should have responded to the CP-2000 with a protest to preserve your right to Appeals. You should have contested the proposed assessment ...

Confusion.  It sounds like the "after-tax plan" was a Roth 401(k), and not a savings/investment account.  I would ask for clarification on the type of account from the employer/trustee, but assuming the money was placed in a Roth 401(k), it sounds like ...

I have not experienced a failure such as this by the former employer, but am not surprised. They should have followed the employee's instructions and rolled both plans into different rollover IRA's. Client failed by not calling you, his tax person, ...