November 21, 1989
TO: PENSION COMMITTEE NO. 17-89
RE: INSTITUTE REQUEST FOR IRS INFORMATION LETTER CONCERNING
REVENUE PROCEDURE 89-52
__________________________________________________________
At its recent meeting, the Pension Committee formed a
subcommittee to discuss operational issues raised by IRS Revenue
Procedure 89-52 concerning Form 5498 reporting upon the death of
the owner. (See Institute Memorandum to Pension Members No. 46-
89, dated October 11, 1989.)
Following a meeting of the subcommittee on November 9, the
Institute prepared the attached request for an IRS information
letter providing further clarification of certain issues. First,
the Institute letter seeks clarification that the procedures in
Rev. Proc. 89-52 do not apply if the surviving spouse elects to
treat the IRA as his or her own. Second, the Institute letter
requests an explanation of the reporting procedures that would
apply if the trustee receives notice of the owner's death after
January 31 of the year following the year of death, but before
May 31. Third, the letter asks the IRS to address the impact of
the revenue procedure on the general reporting rules for
accounts to which no contributions have been made for the
applicable year.
We will keep you informed of further developments.
Kathy D. Ireland
Associate General Counsel
Attachment