Individual M has a traditional IRA, a dormant sole proprietorship plan and a corporate plan (all plans have a 12/31 year end). M attains age 70-1/2 during 1999. M proposes to terminate the two qualified plans during 1999 and transfer the qualified funds to the IRA. Since M attains age 70-1/2 during 1999, it is my opinion that M must make the Required Minimum Distribution separately from each the Keogh and corporate plans, prior to rolling the balance of funds to the IRA.

Does anyone believe that M is entitled FIRST to transfer the qualified funds to the IRA and then take a single RMD from the IRA prior to April 1, 2000 (RBD).

Thank you for your comments.

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Think you're right about having to pocket the RMD first, at least in the view of the IRS -- Prop. Treas. Reg. 1.401(a)(9)-1, Q&As G-1A, G-1B.

[This message has been edited by Dave Baker (edited 06-17-99).]