If an Individual Retirement Account’s terms and administration allow a disclaimer (not all do), a custodian likely would recognize only a disclaimer that, besides meeting all conditions to be valid under a relevant State’s law, also meets all conditions to be recognized under Internal Revenue Code of 1986 § 2518. Among other conditions, the disclaimer document must be delivered to the IRA custodian no later than nine months after the date of the participant’s death (or the date the beneficiary attains age 21, whichever is later). 26 C.F.R. § 25.2518-2(c)(1) https://www.ecfr.gov/current/title-26/chapter-I/subchapter-B/part-25/subject-group-ECFRac39af22636eabc/section-25.2518-2#p-25.2518-2(c)(1).
In the Internal Revenue Service’s view, an amount paid over to a State’s abandoned-property administrator is subject to Form 1099-R tax-information reporting and IRC § 3405 Federal income tax withholding (to the extent of an amount not previously so treated).
Rev. Rul. 2020-24 https://www.irs.gov/pub/irs-drop/rr-20-24.pdf
Rev. Rul. 2019-19 https://www.irs.gov/pub/irs-drop/rr-19-19.pdf
Rev. Rul. 2018-17 https://www.irs.gov/pub/irs-drop/rr-18-17.pdf
The facts BruceM describes suggest the IRA custodian might treat the son as the person entitled to the unclaimed benefit. If so, and if the IRA custodian tax-reports, the Internal Revenue Service (and perhaps State and local tax authorities) might presume the son received income.