Update re PLR 200720023 – Partial Transfers Still

L1: Update re PLR 200720023 – Partial Transfers Still Hello,
Since this topic first came up, we have been in touch with the firm that requested the PLR.
In their words:
“IRA Y did not pre-date the transfer of assets from IRA X and IRA Y was not funded prior to the first trustee-to-trustee transfer from IRA X.”
This seems pretty clear. No commingling of non-SEPP assets took place.
It would appear that this PLR closes down the partial transfer industry.2007-06-07 13:47, By: alanpp, IP: [12.42.51.28]

L2: Update re PLR 200720023 – Partial Transfers StillHi,

Having read and reread PLR 200720023, I’m concerned. In 2006 I started my 72T plan naming three IRA accounts held Fidelity as being my 72T universe with distributions coming from only one of the three accounts. I transferred the balances of two accounts to a single account with TD Ameritrade, where I further transferred about _ the balance (this year) to a third custodian for a self-directed IRA. So far I have transferred dividends multiple times from TD Ameritrade back to the Fidelity IRA account that makes the 72T distrubtions, but have not yet transferred dividend from the self-directed IRA to Fidelity. So the 10% tax plus penalties question is am I screwed according to the PLR?

Thanks for your help,
Don 2007-06-07 15:17, By: dond, IP: [24.32.37.113]