(decedent died intestate with IRA having no designated beneficiary and three intestate heirs; estate administrator sought ruling that division of IRA into separate IRAs for each intestate heir via trustee-to-trustee transfer would not be a "transfer" that would trigger IRD for the estate by virtue of I.R.C. Sec. 691(a)(2); IRS determined that probate estate not "designated beneficiary" under I.R.C. Sec. 401(a)(9)(B); consequently, IRAs distributable over five years and not over lifetime of each respective heir).