Decedent was a Pennsylvania resident. Decedent passed away with no named beneficiary for his IRA. Executor has had custodian transfer IRA account title from decedent’s name and Social Security number into estate name and EIN. No distributions have been made to date.

Estate’s attorney is advising that the IRA must be distributed to the estate and the estate must recognize the taxable income. Custodian of IRA has stated that the IRA can be split into separate accounts for each beneficiary of the estate, who will then recognize income.under non-spouse inherited IRA distribution rules. I am looking for the correct answer as well as the authoritative citation.