In an unusual move that ended up favoring IRS, and invalidating a longstanding IRS position favoring taxpayers, the Tax Court has altered the landscape when it comes to individual retirement act (IRA) rollovers.1 Effective January 1, 2015, taxpayers will be able to roll over fund assets, tax-free, in an IRA to IRA rollover, only once in any one-year period.2 Although IRS authority has been to the contrary, allowing IRA-to-IRA rollovers once in a one-year period for each IRA account, IRS now agrees that the roll over rule now limits such roll overs to one per year for all IRA accounts.3