How to dispute a FMV provided by custodian for RMD purposes

[Anonymous]

my thread comes from the article you cited.  why not give him a call and see if he can recommend anything including an valuation expert. but you are right. if the custodian submits a 1099R for $230K and someone values it at less, how do you justify it to the IRS.  my guess is you would have to go for a PLR.  (costly and without the insurance company valuation computation, the IRS may decline to rule)     another possibility is a lawyer that specializes in insurance law.    you should be able to find one by contacting your state or local bar association. 

maybe contact a large CPA firm. they may have people who do valuations because they do multimillion $ estate returns  where they provide certified valuations.   but again it will be them against the insurance company.      

[Critter]

Just a thought ... if they did cash out the annuity and the death benefit was forfeited then the value of the account could not possibly include the death benefit any longer ... their figure on the 1099-R should only reflect the actual FVM of the contract.   And to avoid this artificially high value from inflating the 2020 RMD then this will need to be done this month. 

[LizaBBBB]

i went thru this with a smallish IRA held by National Western Life. I enlisted the help of our State's Office of Insurance Regulation. NWL has been using accumulation value as FMV. I got ot changed to cash value (works if no riders or other sopecial provisions). 

[LizaBBBB]

i went thru this with a smallish IRA held by National Western Life. I enlisted the help of our State's Office of Insurance Regulation. NWL has been using accumulation value as FMV. I got it changed to cash value (works if no riders or other special provisions). 

[dmertz]

Because a surrender change could be avoided by taking the RMD for an IRA annuity from another of the individual's IRAs (assuming that the individual has such an IRA), it seems inappropriate that FMV of the annuity for RMD purposes would be reduced by the amount of a potential surrender charge.  With sufficient funds in the other IRA, all IRA RMDs could be satisfied from that other IRA until the surrender charge for the IRA annuity ages out.  I would also expect that the IRA annuity contract would waive surrender charges for RMDs.

RMDs are a federal requirement, so it seems odd that a state authority would have any say in this.