At age 65, Carmine's financial position was better than her health. She had a large balance in an IRA that she wanted to move to a different IRA. Carmine withdrew $100,000 from the IRA and planned to roll over the funds into another IRA. Unfortunately, she died before completing the rollover. Carmine's son, Antonio, discovered what his mother had done a week after her death. Antonio was both the executor of Carmine's estate and the beneficiary of her IRA.

1. Identify the tax issue(s).
2. Locate and review the IRS pronouncement(s) that deals with this situation and address the issue(s). Hint: you should search only in Private Letter Rulings and also in the Internal Revenue Code.
3. Prepare a research memo.
   1. Review pgs. 350-353 of text for items that should be included in the research memo.
   2. Review the rubric below for how your written submission will be graded.
4. Write a brief paragraph that details how you found your answer using the RIA Tax Database. Include the keyword(s) you used and steps completed for your search.