CPA newbie or ?

L1: CPA newbie or ?Hi,I met with a new CPA today to talk about setting up a single 72t across multiple accounts with the possibility of multiple trustees in the future and being able to transfer SEPP identified monies within the SEPP universe. The CPA has been in business for over twenty years and had done some 72t plans, but was unfamiliar with the multiple accounts/trustees single 72t angle. His experience was setting upsingle 72t plans onsingle IRAs. He cited the following underlined text from the IR Bulletin 2002-42 that made him think multiple accounts were a 72t buster.
(www.irs.gov/pub/irs-irbs/irb02-42.pdf)Page 4 of the PDF file:”(e) Changes to account balance. Underall three methods, substantially equal periodicpayments are calculated with respectto an account balance as of the first valuationDate selected in paragraph (d) above.Thus, a modification to the series of paymentswill occur if, after such date, thereis (i) any addition to the account balanceother than gains or losses, (ii) any nontaxabletransfer of a portion of the account balanceto another retirement plan, or (iii) arollover by the taxpayer of the amount receivedresulting in such amount not beingtaxable.” Given the questions and answers that I have read in this forum, I don’t believe the CPA is correct. Can anyone give me pointers to IRS docs that I can pass on to the CPA so he can feel more comfortable? I have been searching the IRS web site till my head was hurting and wasnot finding anything useful.Thanks again for your help. Please see my previous post title: “Yellow duckie fan – 72t proposal” for more background on what I’m trying to do. CY2006-02-10 01:01, By: Curious Yellow, IP: [24.32.37.113]

L2: CPA newbie or ?Hello CY:
There is no question that the language you cite (which is from Revenue Ruling 2002-62) is absolutely terrible and confusing. It took me a couple of reads to get it right. Tell your accountant to:
1. Read PLR 199525062.
2. re-read IRC 408(d).
3. Re-read RR 2002-62 in the context that cited (e) above applies only to the extent that such a transaction CHANGES or modifies the distribution stream of taxable payments.
Regards
TheBadger
wjstecker@wispertel.net
2006-02-10 06:52, By: TheBadger, IP: [66.250.23.25]

L2: CPA newbie or ?Thanks “TheBadger” for the information. I had a heck of a time findingPLR 199525062. I thought I could go to the irs.com site and search for it, but no luck.
I eventually found it athttp://www.legalbitstream.comunderPrivate Letter Rulings, but the PLR was listed as 9525062 as opposed to 199525062.
I also found IRC 408 at
http://www.irs.gov/pub/irs-tege/irc408.pdf
And RR 2002-62 at
http://www.irs.gov/pub/irs-drop/rr-02-62.pdf
Thanks again – CY2006-02-12 01:18, By: Curious Yellow, IP: [24.32.37.113]