Phyllis maintained an IRA account at the brokerage firm ABC. On February 11 of the current year, she requested a check for the balance of her account. She received the check made out in her name and deposited it the same day in a new IRA account at the brokerage firm XYZ. Phyllis then requested a check on May 8 from XYZ, which was deposited in another new IRA account 35 days later. Is the May 8 distribution taxable to Phyllis? Prepare in good form a research memorandum to the file. (See Chapter 2 for an illustration of the structure of a tax memo.)