IRS Position on One IRA Rollover Per Year Rule

In Announcement 2014-15, the IRS stated that it will not change its historical stance that the one 60-day rollover per year rule applies on an IRA-by-IRA basis (instead of on a taxpayer basis) until January 1, 2015.  Recently, in Bobrow v. Commissioner, T.C. Memo. 2014-21, the U.S. Tax Court ruled that the rule applies on a taxpayer basis, such that only one 60-day rollover can be completed by any taxpayer in a single year.   There was no and is no limit on direct rollovers.  The moral of the story is:  When possible, do direct rollovers.