Yes, I get what you are saying: "The repayment is treated as falling under the Rollover provisions. There is no 60-day window, no "one every 12 months" limit, etc."

There is a 2020 1099-R that did not go on the originally filed tax return so taxpayer received an IRS letter.

It needs to be added to the tax return. The distribution had fed/state tax withheld. I assume that I need to indicate that it was coronavirus disaster distribution thereby creating a 8915-E. This creates 2020 taxable income - 1/3 of distribution. This part is fine. I can do this.

From Q7 of the IRS FAQ:

"you may file amended federal income tax returns for 2020 and 2021 to claim a refund of the tax attributable to the amount of the distribution that you included in income for those years, and you will not be required to include any amount in income in 2022."

My question is, what part of the return needs to be amended? Change the distribution code on the amended return from a "1" to "G" so that it isn't included in taxable income and the taxpayer can get his withholding back?