AndyJ is essentially
correct; the
Zack's information is outdated.
I'm a strong advocate of going to the source. However, the "rule" was no rule at all, but a
proposed IRS regulation - having no force of law, just providing clues as to how the IRS would treat your rollovers. Here's one of the clearest discussions of proposed regs vs. final regs vs tax code (statutues) I've seen. It's from CCH and was written for accountants, not lawyers, so it does a good job at clarifying the law.
Tax Research: Understanding Sources of Tax LawSubtitled: Why my IRC [statutes] beat your Rev Proc [IRS regs]!
In this case, the underlying statute (
IRC 408(d)(3)(B)) was clear: if you have done a 60 day rollover within a year, you can't do another tax-free 60 day rollover of money from
any IRA. The court ruling picked up on this wording. The IRS has put its own erroneous spin on the statue for years. It's been writing this into Pub 590 and letting people get away with it.
I'm wondering if there is still a loophole. The new IRS regs (and existing statutes) allow any number of rollover
conversions, i.e. taking money from traditional IRAs, holding the money for up to 60 days, and then depositing it into Roth IRAs as conversions. All these serial Roth conversion could be recharacterized to traditional IRAs (and thus avoid taxes) so long as they were recharacterized prior to the tax filing deadline (including extensions).
So it seems you can do multiple 60 day rollover conversions, and ultimately get the money back where it came from. This isn't quite as flexible as the old 60 day bucket brigade (rolling over the
same money from IRA to IRA), but it still have the effect of getting you access to some amount of money for an indefinite period of time (rather than 60 days per year).
As to extensions of the 60 day restriction, here's the IRS FAQ page on waivers (doesn't seem to help Gary):
https://www.irs.gov/retirement-plans/retirement-plans-faqs-relating-to-waivers-of-the-60-day-rollover-requirement