Missed MRD's for four years

[dhawkcpa]

Taxpayer missed MRD's for 2016 through 2019. Luckily the total shortage was only about $2200. Have never had more than one missed year before and have always been sucessful getting a waiver on 5329 line 54. Line 52 on the 5329 asks for the 2020 MRD for only 2020 which is zero due to the pandemic. Taxpayer emptied the IRA in 2021. Should I just put the entire shortage on the 2020 5329 and beg forgiveness or amend 2016 through 2019? Any other thougths? Many thanks.

[FEDUKE404]

This topic has been discussed previously.
Simplest answer is you need to complete a Form 5329, Part IX for each calendar year where RMD was in play and no withdrawal occurred. Amended returns for each of the four years are likely.
You might get IRS to approve a waiver for year #1, but I doubt if you can get a waiver for all four years.

[Anarchrist]

You can file the 5329 by itself, I don't think you need to amend any of the years.

I've gotten penalty relief for at least two years and I'm sure I've done that more than once. If the client has a good sob story, you should be able to get forgiveness for all four years. Even if they don't have a good sob story, if the ira custodian didn't inform them, you can probably get out of the penalty.

[FEDUKE404]

You can file the 5329 by itself, I don't think you need to amend any of the years.

I've gotten penalty relief for at least two years and I'm sure I've done that more than once. If the client has a good sob story, you should be able to get forgiveness for all four years. Even if they don't have a good sob story, if the ira custodian didn't inform them, you can probably get out of the penalty.

My bad! I had forgotten that Form 5329 can be a stand-alone form.
As for the waiver issue, it does appear just about any "reason" will receive IRS blessing, likely to include multiple years for the same reason.
Just another example of what the IRS selectively chooses to "enforce,"

[RWG1950]

Wouldn't it be a good idea (although it's not likely to happen) to have the current RMD rules changed so that
if the custodian receives no distribution instructions for the current year from the customer by Dec 1st,
the custodian would be required to pay out the year's RMD (net of minimum withholding) each year to the customer
by mailing a check to his or her address of record. Puts the onus on the custodians. No more missed RMD's

[FEDUKE404]

Wouldn't it be a good idea (although it's not likely to happen) to have the current RMD rules changed so that
if the custodian receives no distribution instructions for the current year from the customer by Dec 1st,
the custodian would be required to pay out the year's RMD (net of minimum withholding) each year to the customer
by mailing a check to his or her address of record. Puts the onus on the custodians. No more missed RMD's

I think having an "automatic" RMD from every account might create problems for a taxpayer who has several accounts subject to RMDs. So long as the total dollar amount is withdrawn, for each type of account, it does not matter from which account(s) the funds originated.
At least that's the way the rules used to be. . .