Have a client who in August took $90,000 out of their IRA and redeposited within the 60 day limits. He needs more money and to get around the 12 month rule is going to do create a new IRA with another custodian and do a partial trustee to trustee transfer. He then is going to do a distribution from the new IRA and plans to re-deposit the funds within 60 days. Is this permissible?