Split of rollover plan possible for 72t??

L1: Split of rollover plan possible for 72t??Is it possible to rollover a company plan into an IRA, split the IRA and then 72t only one of the IRAs? PLR 9050030 indicates a rollover IRA can be treated separately from a “regular” IRA – but is unclear on this point. Thank you.
Michele2004-08-15 08:31, By: Michele, IP: [209.114.239.56]

L2: Split of rollover plan possible for 72t??As long as there are two IRAs you can indeed use 72(t) on one. Just keep good records and make sure that the funds stay separate.2004-08-15 08:46, By: Gfw, IP: [172.16.1.74]

L2: Split of rollover plan possible for 72t??Hello Michele:
I suggest you read PLRs 1995-25062 & 2001-22048; they are more on point & clear; e.g. IRC 72(t) does not require the aggregation of all IRAs & a taxpayer id free to commence SEPP distributions on one or more than one of them while holding other IRA accounts on the side.
TheBadger
wjstecker@wispertel.net
2004-08-15 08:49, By: TheBadger, IP: [66.250.23.21]

L2: Split of rollover plan possible for 72t??Thank you for fast response. After posting, I continued to read many of the threads here and located PLR 2003 09028. I’m going to look up the PLRs referenced by The Badger for additional resources. Thank you very much – this is indeed what the web was designed to do and I’m thrilled that it works like this. Your hard work is appreciated.2004-08-15 09:11, By: Michele, IP: [209.114.239.56]

L2: Split of rollover plan possible for 72t??Actually, I have talked with Alan Pipkin about the language in 2003-09028; e.g.”IRC 72(t) and the applicable regulations do not require the aggregation of all IRAs owned by the sametaxpayer for purposes of 72(t)(2)(A)(iv).”
Convienent language but actually wrong. IRC 408(d) does require the aggregation of all IRAs for distribution computational purposes. However, the IRShas choosen to interpret 408(d) as only applicable to RMDs commencing at age 70 1/2 & not applicable to early distributions under 72(q) & (t).
Almost all of the time 72 & 401-416 are linked to each other. How they uncoupled 72 from 408 this time has always been a mistery to me. There are no pronouncements or other written logical documentation to support it. OTOH, I was always taught “to not look a gift horse in the mouth”.
TheBadger
wjstecker@wispertel.net
2004-08-15 09:32, By: TheBadger, IP: [66.250.23.21]

L2: Split of rollover plan possible for 72t??Interesting note on your follow up. I’m showing my age here – what does OTOH mean? Thanks, Michele2004-08-16 07:46, By: Michele, IP: [209.114.239.56]

L2: Split of rollover plan possible for 72t??OTOH = “on the other hand”
TheBadger
2004-08-16 07:57, By: TheBadger, IP: [66.250.23.21]