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On March 20, 2014, the IRS quickly responded to the Tax Court decision in Bobrow v.Commissioner stating that it anticipates following the Bobrow decision on IRA Rollovers. The IRS intends to clarify that the rules limiting IRA rollovers to one during a 12 month period should be applied on an aggregate basis. Click here to read: Update on IRS Developments Concerning The Recent Tax Court Decision on IRA Rollovers.