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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M must take a minimum distribution from EACH plan, based upon each plans' 12/31/98 value. After M takes the RMD, the balance can be rolled into an IRA. That rollover will then be reflected in the 2000 distribution, based upon the 12/31/99 balance.