"Taxpayer A completed a request for a direct rollover from Plan C to Financial Institution F.... Financial Institution F received two checks from Financial Institution G, the third-party administrator for Plan C. One check ... represented contributions and earnings in Taxpayer A's designated Roth account under Plan C. The other check represented pre-tax elective deferrals and earnings thereon under Plan C. Accompanying the checks was a letter from Financial Institution G that explained the two checks. Financial Institution F, however, deposited both checks into Taxpayer A's Traditional IRA D."