Forgive me if this is the wrong way to communicate with mtm moderators directly.
Earlier today, I submitted two postings to mtm. Their contents are excerpted below from the ack message.
Both postings can be deleted, if you wish.
I have decided not to pursue the matter. So the questions are irrelevant and a waste of responders' time, notably Ira Smilovitz's.
----- excerpt #1 -----
Message-ID: snipped-for-privacy@googlegroups.com
> Subject: Re: One-per-year rollover limitation?
> From: snipped-for-privacy@gmail.com
> Injection-Date: Wed, 22 Apr 2020 16:50:32 +0000
> To: snipped-for-privacy@moderators.isc.org
> > > > If I withdraw $10,000 from IRA-1 and $20,000 from IRA-2, then within
> > > 60 days of the earlier withdraw within the same calendar year, can I
> > > rollover $30,000 into IRA-3? Or is that considered 2 rollovers in
> > > the same 1-year period?
> >
> > That's two rollovers.
>
> Thank you for your interpreation. Assuming you are correct, I am
interested in pursuing this with the IRS in some manner, in the hopes of getting an alternative interpretation, at least in the context of the CARES Act.
> I would appreciate your guidance on how to proceed.
>
>
> 1. Do I want to request a determination letter or a private letter ruling? >
> According to one website, the difference between a DL and PLR depends on
when the action in question is performed.
> I will submit the request __before__ making any rollovers pursuant to the
CARES Act (i.e. rolling over waived RMDs from multiple IRAs before July 15).
> Is there any other form of request that I can pursue?
>
> I am interested in an IRS interpretation that applies to everyone,
including myself, who has followed IRS rules for satisfying the RMD requirements for multiple IRAs, and who want to "reverse" those withdrawals pursuant to the RMD waiver and the 60-day rollover extension in the CARES Act.
>
> 2. What are the fees for the request?
>
> According Appendix A(A)(1) of IRB 2020-1, the 2020 fee is $275 for a DL. >
> The fees for a PLR under Appendix A(A)(3) et seq are significantly
higher. And it is not clear to me which, if any, of those situations applies for my purposes.
>
> 3. Can you provide authoritative citations for your interpretation;
specifically, that withdrawals from two Traditional IRAs cannot be combined and treated as a single rollover?
> I would like to include such citations in my request to the IRS. >
> I am looking for applicable language in the IRS code (26 USC), IRS
regulations (26 CFR), or other IRS documentation (IRB, IRS Notice, DL, PLR, etc).
> However, I would settle for an explicit example from the IRS Pubs that
matches the facts (again: two Traditional IRA withdrawals that are combined and treated as a single rollover). I might have overlooked it.
> Thanks again.
----- excerpt #2 -----
Message-ID: snipped-for-privacy@googlegroups.com
> Subject: Re: One-per-year rollover limitation?
> From: snipped-for-privacy@gmail.com
> Injection-Date: Wed, 22 Apr 2020 17:21:58 +0000
> To: snipped-for-privacy@moderators.isc.org
> I wrote:
> > > On Friday, April 17, 2020 at 8:02:04 PM UTC-7, ira smilovitz wrote: > [....]
> > > That's two rollovers.
> >
> > I would appreciate your guidance on how to proceed.
>
> And I forgot to ask:
>
>
> 4. How long should I expect the IRS to respond to any request that I submit?
>
> I need to execute __some__ rollover before July 15, less than 3 months from now.