Improper Rollover of a Distribution from an Inherited IRA - Letter Ruling 200228023 dated April 15, 2002

AuthorSeymour Goldberg
ProfessionSenior partner in the law firm of Goldberg & Goldberg, P.C., Woodbury, New York
(APRIL 15, 2002)
(Selected portions of the ruling are provided below)
This ruling involved the improper rollover of a distribution from an
inherited IRA.
According to ruling Taxpayer A, whose date of birth was Date 1,
1936, died on Date 2, 2000. As of the date of her death, Taxpayer A
maintained IRA X with Company M. Taxpayer B, Taxpayer A’s son, was
the named beneficiary of IRA X. The date of death value of IRA X was
Sum 1.
On or about Date 3, 2000, Taxpayer B received a distribution of the
Sum 1 value in IRA X. Company M issued a calendar year 2000 Form
1099- R to Taxpayer B indicating that he had received a distribution in
the amount of Sum 1 as the beneficiary of Taxpayer A’s IRA X.
On or about Date 4, 2000, Taxpayer B rolled over a portion of said
distribution into IRA Y, an individual retirement arrangement main-
tained with Company N. Documentation submitted with your ruling
request indicates that IRA Y was designated a “Beneficiary IRA Rollover
to be maintained for the benefit of Taxpayer B.”
On or about Date 5, 2001, Taxpayer B rolled over the remaining
portion of the Date 3, 2000, distribution from IRA X into IRA Z, an
individual retirement arrangement maintained with Company M. Doc-
umentation that accompanied this ruling request indicated that IRA Z
was created by means of a “Rollover Contribution.”
IRAs Y and Z were set up using Taxpayer B’s Social Security number.
According to the IRS:
1. That the transactions described above, through which Sum 1 was
distributed from IRA X and subsequently rolled over into IRAs Y

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