While not they do not provide precedent, the PLRs give an indication of the IRS position on this and consistently suggest that the IRS generally does not have a problem with transferring a inherited IRA out of the estate to estate beneficiaries; I've never heard of a case where the IRS provided a ruling denying this. There are apparently IRA custodians that are accommodative of doing this without a PLR and Natalie Choate's suggestion in the original reference was to find one of those IRA custodians and transfer the IRA for the benefit of the estate to them. It seems to me that this would be impossible only if the original IRA agreement explicitly prohibited the transfer of an IRA inherited by the estate, which would be a restriction imposed by the original IRA custodian, not by statute.
