spousal rollover under new proposed regulations

[Guest Kurt_Johansen]

My review of the new proposed regulations leads me to believe that a spousal rollover can be made at any time after the death of the IRA owner as long as the minimum distribution has been made to the IRA owner. So that seems to mean that a surviving spouse could take required minimum distributions from the IRA for 20 years and then roll over the IRA if the surviving spouse so elected.

Furthermore, there does not seem to be any rule that would prevent a surviving spouse from taking a partial distribution from the IRA as a beneficiary and then doing a spousal rollover of the remaining account. This is significant where the spouse wishes to take a distribution of some of the account and is under age 59 1/2.

Does anyone disagree with my analysis? Noel, I would love to hear your opinion.

Kurt