Beech v. Comr., T.C. Sum. Op. 2012-74

(petitioner inherited IRA from her mother and rolled the funds into her own IRS within 60 days; rollover triggers income because petitioner was not spouse of decedent and no trustee-to-trustee transfer occurred; no substantial compliance allowed because I.R.C. Sec. 408(d)(3)(C) expressly denies rollover treatment to inherited IRA).