Client receives a small (~$ 250.00) distribution from 401k each year,.   He does not have enough $$ in the account for the account trustee, so Fidelity sends him a distribution check with taxes withheld.  He deposits the gross amount into his IRA right away (he makes up for taxes withheld to equal the full amount of the distribution). 

How should I treat this distribution?  Client insists its a rollover.