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Yes, the pro rating done on Form 8606 will result in most of the conversion being taxable if she has this SEP balance on 12/31/2020. As you indicated, she can avoid the tax by making the 2020 SEP contribution in 2021 by the due date or by the extended due date of 10/15 if she files a timely extension for her 2020 return. If she has not made a 2019 contribution, she also has 2 days to make that ND contribution in addition to the 2020 contribution she will make. She could then convert them in a single 14k tax free conversion. Of course, once she does fund the SEP IRA, that will compromise future back door Roth conversions after this year. One solution is to fund a solo K instead of the SEP IRA since that will eliminate the pro rating issues as well as the potential for a larger contribution than she could make as a SEP contribution. In addition, starting with 2020 contributions, a solo K can be established later than in the past. For 2020 contributions the solo K only needs to be established by the due date plus extensions for filing the 2020 return, so there is plenty of time to consider this.