Quote Originally Posted by Kram BergGold View Post
I would have her get all the distributions. They will be taxable in 2017. I would file a stand alone 5329 for each year asking for a waiver. A key is to have her set things up for automatic yearly withdrawals. So you can tell IRS this will not happen again.
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!