I am not going to look it up and study it myself, but there is a rule whereby the 60-day rollover period can be waived in certain circumstances. If anyone who reads this Board knows those rules hopefully they will either confirm that it's worth looking into or explain why it can't be used in this situation. Short of that you can find it somewhere in IRC Section 402. With all that said I think you need IRS blessing for this via a private ruling and depending upon the user fee and other costs associated with that it may not be worthwhile just to defer the tax on $10,000.