Aggregating RMD from inherited IRAs- when is it allowed?

[Appleby]

I have always understood from all the books I have read on the topic, that the beneficiary may aggregate RMD for inherited IRAs from the same decedent...But a poster at another forum indicated that one financial institution has indicated that the aggregation rule does not apply if the IRA owner dies on or after the RBD. §1.408-8 Q&A 9 seems to suggest that this is correct, as it states in part “…However, amounts in IRAs that an individual holds as a beneficiary of the same decedent and which are being distributed under the life expectancy rule in section 401(a)(9)(B)(iii) or (iv) may be aggregated, but such amounts may not be aggregated with amounts held in IRAs that the individual holds as the IRA owner or as the beneficiary of another decedent.”

The question then becomes, “ why does it appear that aggregation is limited to 401(a)(9)(B)(iii) or (iv), which applies to the life expectancy option when the participant died before the RBD? And does not appear to include 401(a)(9)(B)(i) which applies to when the participant died on or after the RBD?”

Am I missing something?

[jevd]

Appleby,

I think it is an IRS oversight. Not suprising.

[Belgarath]

Maybe someone with actual audit experience can answer this: I wonder, from a purely practical viewpoint, how likely it is that the IRS would pick up anything like this on audit? By that I mean - do they actually look at the IRA document to determine if it is inherited or not, or do you just show them a bunch of statements with the account balances, clculate a minimum distribution for each, then prove via the 1099's that you took the required amount?

I truly have no idea - just wondered if the risk is perhaps insignificant? On the other hand, how difficult is it to play it safe and just take a distribution from each if there's any question? I always believe in playing it safe on any questionable item like this, but others are often less conservative.