RMD With an IRA and a 401(k) Account

[Guest MFuentes]

A person reaches 70 1/2 in 1999 and is required to take a minimum distribution. He has several IRAs and has an account in his employer 401(k) Profit Sharing Plan (with match). He's still working but wants to take his minimum distributions. The IRS Prop Reg §1.401(a)(9)-1, Q&A H-1, requires that each plan to separately satisfy IRC §401(a)(9), but Notice 88-38, 1988-1 C.B. 524, allows IRAs to be aggregated for purposes of determining his RMD. I can't find a rule the prevents the distribution from the 401(k) from satisfying the IRA RMD rules. It seems clear the distribution has to come out of the 401(k) but less clear that a distribution from the 401(k) wouldn't satisfy the RMD for the IRAs. Any thoughts, or more specifically, sites why the participant couldn't do this?

[This message has been edited by mfuentes (edited 12-06-1999).]