No waiver is allowed when a filer dies before completing a rollover.
The Service privately rules. In this case, a retiree took a payout from his firm’s plan and died before he was able to complete a rollover to an IRA. The Revenue Service declined to waive the 60-day deadline, saying that it’s impossible for the deceased to finish the rollover. And since he received the plan distribution before he died, his wife is precluded from making a tax free transfer into her own retirement account.
Remember the Service is out to get our money, this is their job and the laws are written in their favor.