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5500 Preparer's Manual for 2012 Plan Years
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CCH® PENSION AND BENEFITS — 5/22/08

Distributions from decedent’s IRA to beneficiary calculated based on life expectancy of beneficiary

The IRS has privately ruled that the required minimum distributions (RMDs) from a decedent’s two IRAs could be calculated for all past and future years based on the life expectancy of the beneficiary as determined under the Single Life Table of Reg. §1.401(a) (9)-9 . The decedent had two IRA’s with the same designated beneficiary. The beneficiary took several years worth of required minimum distributions in one year, paying the appropriate additional tax for failing to take the RMDs in the years when they should have been taken under the Code.

The failure to timely make Code Sec. 401(a)(9) required minimum distributions did not affect the calculation of required minimum distributions for subsequent years, and did not necessitate the use of the five-year rule of Code Sec. 401(a)(9)(B) (ii), where the taxpayer had not elected the five-year rule.