Distribution of RMDs before Conversion

[Guest kprhok]

It is my understanding that, for individuals who have attained age 70.5, the IRS will consider the first dollars that are paid from IRAs during a Distribution Year to be in satisfaction of their RMD for that year.

If an individual completes a Roth Conversion of one IRA, and later takes a distribution from another traditional IRA "to satisfy his RMD requirement for the year", am I correct in thinking the IRS would consider the first transaction (the Roth Conversion) to be an ineligible rollover up to the amount of the taxpayer's RMD for the year, and subject to an excise tax (treated as excess contribution to Roth)?

My reference point is Treasury Regulation 1.408(a)(4), Q- A 6 which states, in part..© If a required minimum distribution is contributed to a Roth IRA, it is treated as having been distributed, subject to the normal rules under section 408(d)(1) and (2), and then contributed as a regular contribution to a Roth IRA. The amount of the required minimum distribution is not a conversion contribution.

I am looking for cases, rulings, etc where this scenario is discussed - where the taxpayer converted an IRA to a Roth prior to having satisfied his/her annual RMD requirement. Thanks!!