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My shoot-from-the-hip answer? Assuming she's not too old and is eligible to convert, and assuming the kids are going to let it grow for a good while before tapping into it, then convert all of it and pay the tax from outside the IRA (even if it means selling stock to generate the cash to pay the tax). Ending up as beneficiaries of a $600K Roth should be better for the kids than a $100K Roth and a $700K traditional IRA, especially considering the kids are high-bracket taxpayers.

The conversion will also reduce the estate tax by taking about $200K out of the taxable estate. Keeping the traditional IRA would give the kids an income tax deduction for the estate tax attributable to the IRA's inclusion in Mom's estate, but I doubt that would offset not having to pay any tax at all on a 30% or so smaller amount that compounds and gets distributed entirely tax free.

Anyone see it differently?
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