ID: Office: UILC: CCA_2011050611141650 ------------------------- 72.00-00 Number: 201123031 Release Date: 6/10/2011 From: -------------------- Sent: Friday, May 06, 2011 11:14:25 AM To: ---------------------------------------------- Cc: Subject: RE: PT attribution rules question For purposes of section 4975(e)(6) of the Code family members only includes the following: • The IRA owner’s (which in this case would be the fiduciary of the IRA under section 4975(e)(A) and section 4975(e)(3)) spouse • Ance stors (Mom, Dad, Grandparents) • Lineal Descendents (daughters, sons, grandchildren) • Spouses of Lineal Descendents (son or daughter-in-law) Therefore, in this case the taxpayer's brother in-law and parents in-law would not be considered family members u nder section 4975(e)(6) of the Code, because section 4975(e)(6) refers only to the spouse of a lineal descendent .