Excellent approach, as that 50% penalty can be quite painful.
My concern would be whether the IRS will feel "kind" for what was/is a recurring mistake. I've only had to deal with "Year #1" penalty waivers, and they all went through fine.
One issue: If she runs the table to make peace with the IRS by taking the earlier RMD withdrawals "late," she might really get her clock cleaned for the 2016 (already filed?) and/or 2017 returns due to the income boost. She might even find herself wandering into the Land of IRMAA!

FE

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