Trade publication Investment News has an article dealing with IRS treatment of botched IRA rollovers (I'd link to the article but I can't).

Based on recent IRS private letter rulings, here's what a claim must show if there is any shot of the IRS waiving the 60 day rule (Sec. 402(c)(3)(B) of the Internal Revenue Code):

1. original intent to execute the rollover but for an intervening event or circumstance;

2. an intervening event or circumstance, usually characterized by some form of hardship, whereby it would be "against equity or good conscience not to" allow a waiver.

The article cites two private letter rulings that demonstrate IRS thinking on this matter (remember these rulings are for informational purposes only and can't be relied on for precedent, they only apply to the case at hand).

This waiver was granted.

This waiver was denied.