The Tax Court has recently held in Bobrow v. Commissioner (TC Memo 2014-21) that the one-rollover-per-year rule applies to all of a taxpayer's individual retirement accounts (IRAs) rather than to each IRA separately. The court's ruling conflicts with guidance given by the IRS in Publication 590.

According to Publication 590, a taxpayer with two IRAs could withdraw money from the first IRA and within 60 days, roll over the withdrawal into an IRA (the same IRA or a new IRA). Then, later that same year, the taxpayer could make a withdrawal from the second IRA and within 60 days rollover the withdrawal into an IRA (as long as the IRA was not the first IRA or the IRA that received the first rollover).

The Tax Court held that the Section 408(d)(3)(B) limitation applies to all of a taxpayer's retirement accounts and concluded that only one rollover was permitted during any 12-month period, no matter how many accounts a taxpayer might have.

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