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Tax Court Takes Restrictive View of One Year Limitation on Indirect IRA Rollovers (PDF)
Groom Law Group Link to more items from this source
Feb. 11, 2014

"The Tax Court simply held that the first distribution ... was a tax-free indirect rollover, but as the second distribution was made within a year of the first, it was a taxable distribution ... The court did not consider any [prior IRS] 'guidance' -- nor did it review the private letter rulings in this area that similarly support a per-IRA interpretation. Instead, it focused on the plain language of the statute and the broad legislative history intended to limit repeated shifting of nontaxable income in and out of retirement accounts." [Bobrow v. Comm'r, T.C. Memo. 2014-21 (Jan. 28, 2014)]

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