Minimum Required Distribution vs. In-service withdrawal

[Guest JWBrown]

Here's the scenario: employee age 72 takes in-service withdrawal of entire plan balances during first quarter of 2000, then retires in second quarter 2000.

His required beginning date is April 1, 2001, and his first distribution calendar year is 2000.

Is it proper that part of his in-service withdrawal from earlier in the year be not eligible for rollover, with the amount not eligible determined by the account balance on December 31, 1999 (the last valuation date of the year prior to the first distribution year)?

Thanks.

[bzorc]

In my opinion, you are correct.