@sandy4042 , the question is not whether or not you are subject to the 10-year rule, you are. The question is whether or not you are subject to annual RMDs, which you are because the original IRA participant died after the required beginning date for RMDs.
It's a lot to wade through, but the proposed regulations are here:
https://www.federalregister.gov/documents/2021/09/15/2021-19713/annual-reporting-and-disclosure
