Our customer John had an IRA with his wife Sally named as beneficiary. No contingent beneficiary was named. Both are deceased. The successor trustee, their CPA, just learned of the account and has requested that funds be distributed. Our legal department is advising that the check be issued to the estate of Sally; however, the CPA has advised that her estate was small enough to fall under CA's small estate provisions, so no formal estate was established.
How should we handle this situation. Our operations area is concerned about the reporting. There is no EIN for Sally's estate for reasons mentioned above.