Following the Bobrow v. Commissioner (TC Memo 2014-21) decision, taxpayers discovered that, despite what the applicable IRS publication said, that once a taxpayer had completed a rollover from an IRA account the taxpayer had to wait another year to make a second rollover—even if that rollover came from a different IRA account.

But traditional IRAs aren’t the only type of tax advantaged account for which rollovers are allowed—Coverdell Education Savings Accounts (the accounts originally known as Education IRAs) are also eligible for rollover treatment found at IRC §530(d)(5) that is very similar to the language found at §408(d)(3)(B) the court opined on in the Bobrow case. So do the same restrictions apply?