MRD involving both an IRA with funds and a separate IRA annuity -- how

[BPickerCPA]

First of all, it is not enough that the taxpayer be married, the spouse must be the designated beneficiary as of the required beginning date.

Even assuming that the spouse is, this is a gray area. The IRS has never dealt with this question directly, but in PLRs have hinted at an answer, in a case where a taxpayer has elected single life payout even though a joint life payout was available.

Unfortunately, in cases where the answer has been hinted, it hasn't been consistent. One PLR made it sound like the taxpayer himself was stuck with single life, another made it sound like he wasn't. These are my interpretations, so take it for what (not much) it's worth.

The suggestion from here is that you take the RMD from the second IRA as if it stood on its own. Your other alternative is to get your own ruling. While that could run into money, at least then I'LL have an answer for next time!

[Guest Malou]

The situation involves an IRA annuity that has been annuitized -- that is, it is in payment status. The annuity calculation is based on single life status. The IRA holder is married, and therefore, could use joint life expentency to generate a lower MRD. When the assets of the IRA annuity and the other IRA are combined, the current payout from the annuity alone does not satisfy MRD on a joint life basis. Can the payout from the IRA annuity be considered in determining the amount that must be taken from the other IRA, or must the second IRA's payout stand alone as an MRD calculated on that IRA's value as if the annuity payout did not exist?