The SPIA distributions will not be penalty free before age 59.5 because they will not be calculated using one of the 3 approved methods for 72t payments per RR 2002-62. While not recommended, you could first do non reportable transfers to establish two IRAs, one at an insurance company offering IRA annuities, and then use both IRA accounts for your opening balance to calculate your 72t plan distributions just before the IRA annuity is annuitized. Then annuitize the IRA annuity and subtract the annual payment from your total 72t plan calculation. You would then distribute the difference from the other IRA, so that the 1099R forms would total up to the annual 72t plan calculation, and you would have a legal 72t plan using distributions from both IRA accounts. As you can see there are some complicated plan execution requirements when adopting this approach and complexity adds to the risk of execution error and to IRS scrutiny of the plan. Perhaps the largest issue is that an SPIA at age 52 carries much opportunity cost risks because this money is tied for life and you have lost control of the principal should you need to access a large amount for some purpose in the coming decades. Finally, when you annuitize an IRA before 70.5 the first annuity payment becomes your RMD required beginning date, so even after the 72t plan ends at 59.5 you cannot roll over any of the annuity payout because they are RMDs. Ideally, you would postpone any SPIA purchases until your 70s.

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