Determining Account Balance When Starting SEPP

L1: Determining Account Balance When Starting SEPPI want to start a SEPP now and take the first distribution on June 24, 2005. There would thereafter be one annual distribution on that date.
Let’s assume that the balance of the subject IRAon 12/31/04 was X.
Let’s assume that between 12/31/04 and today I transferred Y intothe subject IRA from another IRA.
When I calculate the SEPP amount that I may withdraw, am I limited to using X as the account balance or may I use X plus Y?
Thank you.2005-06-11 05:33, By: MichaelK, IP: [205.188.117.9]

L2: Determining Account Balance When Starting SEPPRev. Rul. 2002-62, Section 2.02(d) states The account balance that is used to determine payments must be determined in a reasonable manner based on the facts and circumstances.’
In my opinion, the only reasonable account balance that you should use is the account balance after the transfer occurs and all SEPP assets have been defined. However, also remember that it isn’t really necessary to combine all SEPP assets into 1 IRA Account, you merely have to define the IRA balances that will be part of your SEPP universe and use that as a starting point.2005-06-11 06:07, By: Gfw, IP: [172.16.1.70]