accidental IRA distribution

Ouch! I had 50K shares of a restricted (but legend has been lifted) stock in a Merrill IRA. I tried to transfer the shares to a different IRA with a different vendor. I then closed/canceled the Merrill account because there was nothing left there. Unfortunately, the "new" IRA vendor did not accept resctricted shares and they sent them back to Merrill a few days later. Merrill then sent me a certificate (at least I assume it was Merrill...someone did) for the 50K shares which was misunderstood/misplaced/whatever. This was all done in late April 2006. Unfortunately, I've only today (November 2006) figured out what the hell transpired and unbeknownst to me i've taken a distribution from the IRA! I "found" the stock cert today. I obviuosly have not used the proceeds from the so-called distribution, and i most certainly did not intend to take one. It is my responsiblity in the end (should have paid more attention to what was happening with my accounts) but I was not clued in to what was happening all that clearly either. I stopped listening to all the bad news from my tax man part way through his speech and poked around a bit on the Internet. There is a "non-automatic waiver application" to have the IRS consider waiving the 60-day rule via a "private letter ruling:". My question is whether ANYONE has ANY experience with this mechanism such that I can determine either that I shouldn't bother with the process or whether it's worth giving it a try. Very easy to show that I have not profited by the unintended distribution. Not a cheat, just too busy, a dumbass, whatever. Thanks!