Approved PLR

L1: Approved PLRYesterday, the IRS approved a PLR for the use of annual recalculation used in conjunction with the amortization method. The text is somewhat lengthy along with redacted portions of the ruling itself. As a result, Gordon is going to post it somewhere on the website & should be available for viewing in a couple of hours.
TheBadger
wjstecker@wispertel.net
2004-05-12 12:42, By: TheBadger, IP: [66.250.23.21]

L2: Approved PLRthanks for the heads up. any sense of status or leanings on PLRs on the younger person’s72t situations where the 120% midterm avg seems unfair to link when their withdrawal is for 10-25 yrs for those lucky pre-retirees2004-05-12 12:51, By: ralphccbi, IP: [12.107.192.130]

L2: Approved PLRHello ralph:
If you think about it, any person aged under 60 is young(er); at least I think so. Further, at age 60 one’s life expectancy is still 25.2 years; therefore one could make the argument that use of the 120% of the mid-term applicable federal rate is always a mis-match when having a SEPP discussion. And, I personally agree; then again, I don’t get to make too many of the rules.
That being said, I have one more active ruling in the mill. We are attempting to, in essence, get a higher interest rate throughsome “sleight of hand”; e.g. some more complex mathematics that effectively results in a higher annual distribution.
The IRS has made it clear that they do not like the ruling request. OTOH,they also know that I willnot retract the request; therefore they looking for a mechanism to rule adversely and are having some difficulty doing so.
How this will turn out is anyone’s guess.
TheBadger
wjstecker@wispertel.net
2004-05-12 13:00, By: TheBadger, IP: [66.250.23.21]

L2: Approved PLRwell, i agree 60 is young, i look forward to being young at that age. but sometimes we have reasonable possibilities to use 72t for longer terms.
it doesnt happen often but a 37yr old mother of young child with working husband, she wants to set an income stream with limited withholding like a parttime job would be. but using a “shortish” rate to do her calculations seems limiting.
we also figured if she goes back to work down the road,the income would allow her to up her company 401k contribution to maximize the match and tax deferral and might actually be making money off of what she was withdrawing from her 72t because of the matching $$s!
i appreciate your activism and professionalism. will watch to see if there is hope or if this new recalc thought with amortization could also work for her. 2004-05-12 13:23, By: ralphccbi, IP: [12.107.192.130]