Taxpayer had an IRA. The IRA was payable to a Marital Trust and a Family Trust under a formula contained in the beneficiary designation. Taxpayer died before his RBD. IRA was divided into two shares (one for the marital trust and one for the family trust). Surviving spouse is oldest designated beneficiary, so all distributions are coming out over her life expectancy.

We want to further divide the Family Trust portion of the IRA into 3 parts, one for each kid, liquidate the family trust, and distribute to each kid directly his or her right to receive payments from the IRA subaccount.

I talked with an IRS guy today who said he'd ruled favorably on a similar transaction. He thought late 1997 or early 1998. I cannot find this letter ruling and it's driving my bonkers!!!! Does anyone have any leads or comments?

Thanks!!