"Many were predictably upset that the Tax Court ruled as it did, reversing a long-held tradition and contradicting an oft-stated and oft-published IRS position. Perhaps more upsetting was the fact the IRS brought this case in the first place and didn't give credence to their own published guidance. Regardless of this, the statutory reference to rollovers in the Internal Revenue Code has not changed since 1978, and a plain-language reading of it -- while somewhat ambiguous -- can in all honesty be read as the Tax Court did, limiting rollovers to one per-taxpayer per year. The Tax Court took the position that our lawmakers intended to make access to IRA funds possible, but not so easy as to encourage abuses."

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