I wrote about the Bobrow case here. In Bobrow, the Tax Court adopted a more limited rollover rule than IRS Publications allowed, The Tax Court found that the one rollover per year limitation applied to all of a taxpayer’s Individual Retirement Accounts and Individual Retirement Annuities together, and not separately to each account.
The IRS has now announced that it will follow Bobrow and issue a new proposed regulation and revise Publication 590 to adopt the Tax Court's interpretation of the limitation, but that the new rule won't apply to any rollover that involves a distribution occurring by year-end.
Ann. 2014-15, 2014-16 IRB
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