Of course, this has now become a topic for discussion around the home (home office). Here's another way to understand that difference and why this isn't a 1041 issue:

You borrow your own money in this case. That means not repaying it is Not a forgiven loan; it's a distribution of your money, and the "declared" date of the distribution is the 1099-R, which is issued because clearly, that is not being repaid into your account if you are dead and this is being given to a beneficiary.