Taxpayer has tangible personal property (a promissory note to an unrelated third party) in his IRA. Assume that the fair market value of the note is $100K. If he withdraws the note from the IRA, can he roll over (within 60 days) $100K in cash to a new IRA (he would then hold the note personally). Or, is he required to roll over the note (that is, the actual property that was distributed to him out of his IRA)? Code section 408(d)(3) seems to require that he roll over the actual property received. Any thoughts??? Thanks.

No question. He has to roll over the actual property received.


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Barry Picker, CPA/PFS, CFP
New York, NY