Cecilia died this year, owning mutual funds in her IRA worth $120,000. Under the terms of the IRA, Cecilia’s surviving husband, Frank, was the beneficiary of the account, and he took a lump-sum distribution from the fund. Both Cecilia and Frank were age fifty-seven at the beginning of the year.

a. How does Frank account for the inheritance, assuming that he rolls it over into his own IRA in a timely manner?

b. Would your answer change if Frank were Cecilia’s brother?

Partial list of research material: §408; Rev. Rul. 92-47, 1992-1 C.B. 198; Aronson, 98 T.C. 283 (1992).