June 21, 2006 – In private letter ruling (PLR) 200624070, the IRS has denied a taxpayer request for a waiver of the 60-day rollover limitation, basing its ruling on the taxpayer’s inability to provide evidence of other parties’ errors, or of extenuating circumstances (e.g., death, disability, hospitalization, etc.). The IRS has demonstrated a pattern of notable leniency in granting extensions of the 60-day rollover limitation, but this PLR shows that the Service commonly looks for certain fact or evidence patterns when making its rulings.
In this request, the taxpayer claimed not to know that an account to which he transferred IRA assets for better investment options was not an IRA. The only tangible evidence the taxpayer provided, however, including account documentation, confirmed that the account was not an IRA.
PLR 200624070 may be accessed as follows.