In Reply to: Re: IRA RMD – Year Of Death posted by Jane Peebles on 12/12/03:
Thanks for your help friends. I also asked RIA Editorial to reconcile their two conflicting positions and here is their response:
Mr . Hammill--
Thank you for your inquiry. My reading of Reg. Sec. 1.401(a)(9)-5, Q&A 4(a) leads me to the same conclusion that you state in your email. I agree that the regulation provides that where an employee dies after on or after the required beginning date, without taking a RMD, the beneficiaries should take the RMD before the close of the tax year at issue. The sentence you quote from TAPS 10/18.03(D) does not state this rule clearly (and seems to indicate that the RMD should be made to the deceased employee, rather than the beneficiary). We will change the analysis in 10/18.03(D) to more closely follow the rule in the regulation. However, please know that our outside author is in the process of revising Title 10, and I will submit your question to him so that he can respond (and perhaps provide other legal authority to back up his statement). If we receive any additional information or legal authority regarding this question, we will forward it on to you. Thanks again