Taxpayer retires and decides to rollover entire balance of 401K to an IRA. Total accumulation is $500,000. $50,000 represents employee after-tax contributions. The balance is employer contributions and accumulated earnings. The 401K trustee issues two checks. One check for $50,000 an amount exactly equal to employee after-tax contributions and mailed to employee. The other check is a direct rollover to IRA for $450,000. Question: Is the entire $50,000 considered a non-txable distribution, or must it be allocated between taxable and non-taxable portions (10% non-taxable and 90% taxable) as is required for a traditional IRA distribution given total IRA account is made up of both deductible and non-deductible contributions of the years.