IRA Distributions

Contrast the income effect of the following two scenarios:

Shortly after an individual's death, a taxpayer inherits the decedent's traditional IRA and immediately receives distributions from the IRA.

Shortly after an individual's death, a custodial bank transfers the decedent's traditional IRA into the traditional IRA of a taxpayer who then immediately takes distributions from her IRA.

$($see Ozimkoski, T$.$C$.$ Memo. $2016-228)$ Please please give me correct answer.