I have never heard of any State that required an IRA to be "only left to an estate". The only limitations that I have seen in some States is that if the beneficiary is other than the spouse, the spouse has to acknowledge the establishment of the beneficiary, and that is usually limited to community property States. IRS rules do treat an inherited IRA differently depending on the relationship of the beneficiary to the account holder.
_________________________
The opinions expressed here should not be construed to be those of my employer:
PPDocs.com