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Tax Court Takes Restrictive View of One-IRA-Rollover-Per-Year Rule
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Feb. 5, 2014
"[T]he Tax Court ruled that each taxpayer is limited to one IRA distribution eligible for rollover per 12-month period, regardless of the number of IRAs the taxpayer may have.... [IRS] Publication 590 clearly states that each IRA owned by a taxpayer (not including beneficiary IRAs) is entitled to one rollover-eligible distribution per 12-month period. The Tax Court's ruling also conflicts with previous oral guidance from the IRS, and with language in many document provider's ... model-based and prototype IRA document disclosure statements." [Bobrow v. Commissioner, T.C. Memo. 2014-21 (Jan. 28, 2014)]

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