What happens when a tax court ruling contradicts an IRS interpretation of the tax code? You go with what the tax court says.
Although the IRS has said it’s ok to do one IRA rollover per year, per account, a recent tax court ruling decided that an individual can only do only one IRA-to-IRA rollover total per year, even if he or she has more than one account. And that’s 365 days, not a calendar year. Because of this ruling, the IRS is planning to revise its rules in Publication 590.
What can you do instead? Direct transfers. Direct transfers, which move money directly from one IRA to another rather than passing the money through the account holder, are unlimited.