$6.(15$ points$)$ Locate an administrative source of tax law to answer the following question:

$408($d$)$ identifies that amounts distributed from an IRA are included in gross income, but $408($d$)(3)$ allows for qualified rollover contributions to be excluded from gross income as long as the funds are paid into another IRA no later than $60$ days after distribution from the first IRA. In $2024$ Sam had a large balance in an IRA that he wanted to move into a different IRA. He withdrew $$100,000$ from the IRA and planned to roll the funds into the second IRA. Unfortunately, Sam died before completing the IRA rollover. Can Sam be exempt from the $60-$day rule? Identify the appropriate source for your answer and explain what additional steps need to be taken. $($dig a little on this $$ you may find multiple sources of guidance$).$