I've always thought of it like this - someone retires in 2013 at age 75 (just to keep it simple), they're first distribution calendar year is 2013. If they roll it out to an IRA in 2013 without taking the RMD first, they will never take their 2013 RMD, because the 12/31/2012 balance in the IRA is zero. Therefore, you must take it before you close. That is of course the logic that was used when writing the regs in the first place.