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    #1

    Waiver of penalty

    Page 13-24 of "The Tax Book" under waiver of penalty states that the requirement to first pay the tax (50% excise tax on RMD shortfall) and then file for abatement of the penalty no longer applies. What is the citation for the authority for not paying that tax first? The instructions still require it.
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    #2
    Go to Inst. for form 5329 www.irs.gov/pub/irs-pdf/i5329.pdf

    Page 6 middle column under Waiver.
    You have the right to remain silent. Anything you say will be misquoted, then used against you.

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