I have a sole owner/participant under qualified plan with a valuation date (plan year end) of 8/31/99. The plan has terminated and all amounts were rolled directly into an IRA after 8/31/99 but completed by 12/31/99. Participant/owner turns 70 1/2 on 4/24/00. Seems logical to me that I would use the 12/31/99 IRA balance to calculate the RMD for the 2000 distribution year, but I'm trying to confirm by reading the proposed regs. The proposed regs. seem to be mucking it all up for me. Am I right?

I must be missing something, because I don't see the problem. The plan is an IRA and was, as of 12/31/99. You use the 12/31 balance, for purposes of determining MRD.


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John L. Olsen, CLU, ChFC
Olsen Financial Group
St. Louis, MO
314-909-8818