Bobrow v. Comr., T.C. Memo. 2014-21

(petitioners, married couple, had several IRAs and moved funds in and out of the accounts, claiming that all fund movements were rollovers allowed under 60-day rule on a once-a-year basis; court determined that statute at issue, I.R.C. §408(d)(3), does not apply on calendar year basis but begins on date on which taxpayer withdraws funds; accuracy-related penalty imposed).