Priv. Ltr. Rul. 201212021 (Dec. 27, 2011)

(surviving spouse could transfer pre-deceased wife’s IRA to separate IRA established in his own name via trustee-to-trustee transfer in spite of the fact that wife died before changing beneficiary designation forms from her estate to him; IRS did not apply general rule that would have treated IRA as inherited IRA because surviving spouse was sole beneficiary and estate executor; wife fell ill before getting beneficiary designation changed).