She did not rollover the account to her own IRA?  She just left it sitting there in her late husband's name?  What if she opens an IRA now and deposits the funds into it within 60 days?  She can't rollover the tax withheld, but she can take that out of other funds if she has assets.  I'm not saying such a rollover can be done, I haven't had a client who has made that mistake, but I would research it further.  Maybe someone else here can tell us why it's not allowed.