January 31, 2014
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The Tax Court has invalidated part of IRS Pub. 590, ruling that the one-year rule applicable to a taxpayer's ability to make a nontaxable rollover contribution to an IRA is not specific to any single IRA of a person, but applies to all of that person's IRAs.
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).