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sustain such a challenge. Circular 230 Disclosure 31 I.R.C. § 2039. I.R.C. § 1014(b)(9XA). "P.L.R. 200052006 (Jan. 2, 2001). The IRS has reached a similar conclusion for IRAs in which ... pensions rights bequeathed to charities upon death. See, e.g., P.L.R. 200002011 (Jan. 18, 2000) (taxpayer designated charities as beneficiary of deferred compensation and bequeathed nonstatutoly options to charities: value ... deduction under section 2055(a) for the deferred compensation and value of options); P.L.R. 199939039 (Oct. 4. 1999) (tax-exempt foundations named as beneficiaries of IRAs and qualified retirement plans