I digress from Rick's opinion this time. If your client received two distributions, only one would be eligible for indirect rollover.
The language in §408(d)(3)(B) is very clear that reference of this once-per-year nontaxable 60-day rollover treatment is to the distribution rather than the deposit (whether or not combined). In other words, if your client received distributions from two separate IRAs, only one of these would be eligible for tax-free rollover.
408(d)(3)(B)Limitation.—This paragraph does not apply to any amount described in subparagraph (A)(i) received by an individual from an individual retirement account or individual retirement annuity if at any time during the 1-year period ending on the day of such receipt such individual received any other amount described in that subparagraph from an individual retirement account or an individual retirement annuity which was not includible in his gross income because of the application of this paragraph.
Still an AllStar