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It appears that there are really two issues here.

First is the question: Can anyone use a valuation date other than 12/31/xx to value an account from which §72(t)(2)(A)(iv) SEPP's are going to occur. The answer is an unequivocable YES. Technically, any date is fine as long as that tdate is used consistently year-to-year. However, as a practical matter I would always select a month-end or quarter-end for the simple reason that "external" evidence is handy, in the form of your brokerage statements, should the IRS ever ask for proof.

Second, is your particular circumstance where, as of 12/31/99, you have two accounts: the existing rollover IRA and a 401(k) account "enroute" to the rollover IRA as of 12/31/99. Thus, you will still have 12/31/99 statements for both accounts as the 401(k) money will not have left until 1/3/2000. The answer is simple, you simply elect (to yourselves) to commence SEPP's from both accounts using the 12/31/99 totals (of both accounts) to determine your 2000 SEPP amount using whatever method and assumptions you have chosen to make. Subsequently, the 401(k) account is drained to zero and all of the 401(k) account winds up in the rollover IRA. SO WHAT. You are not prohibited from merging multiple accounts just because you are taking SEPP's from them. Said another way, the movement of the 401(k) assets to the rollover account is really an administrative procedure only.

Hope This Helps

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