Fidelity refusing to use "Q" code for qualified Roth distributions

And to follow up, it turns out that Fidelity simply will never use a Q for anything, ever. A subsequent question drew the following response:

I do understand your point of view to use code "Q" on your Roth IRA 1099-R.

The following is from the 2011 Instructions for Forms 1099-R and 5498:

Use Code Q for a distribution from a Roth IRA if you know that the participant meets the 5-year holding period and: * The participant has reached age 59 1/2, * The participant died, or * The participant is disabled. Note: If any other code, such as 8 or P, applies, use Code J.

Use Code T for a distribution from a Roth IRA if you do not know if the 5-year holding period has been met but: * The participant has reached age 59 1/2, * The participant died, or * The participant is disabled. Note: If any other code, such as 8 or P, applies, use Code J.

As you can see from above, the IRS Tax Reporting Guidelines do offer financial institutions the flexibility to use Code Q or T for Roth IRA distributions. Code Q puts the burden of proof on financial institution to determine if the distribution is qualified or not. Therefore, we have decided to use Code T for all post age 59 1/2 Roth IRA distributions.

There are no instances where we will issue a Roth IRA 1099-R with a Code Q.

While I know that not all investors will necessarily agree with our position, I do hope you understand why we choose this option.