Required Minimum Distribution Q

[Hoosier]

First time I've encountered this: Just discovered that client failed to take RMD in 2006. I know that I'm suppossed to add the penalty to the 4040 return using form 5329. However, I've read that the IRS may waive the penalty if the client makes the RMD soon after discovering the failure to do so earlier and a waiver requested. Therefore, it seems like it may make sense to have the client make the RMD for 2006 immediately, not report the failed RMD on the 1040 and deal with a waiver request for the potential penalty when the IRS sends the penalty letter. Any thoughts or better ideas?

[OldJack]

I just did one. I had the taxpayer file the 1040 without the 5329 penalty. I then prepared the 5329 showing the penalty amount and attached an explanation requesting waiver of penalty. I expect to hear yea or nay from the IRS before next tax season.