After looking over my old custodians records (NFS) I noticed that they started my withdrawals August 1st 2017 with only 1 IRA $715K approx and a distribution of $1500.00 then they split it into two IRAs in MID August and September 1st thru December took withdraws of $1800.00 (is what I original told them to do) from IRA1 with $535K after the split IRA 2 is not taking any withdraws dose this seem like it is going to be ok come tax time.
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Permalink Submitted by Alan - IRA critic on Wed, 2018-01-03 21:26
It is rare that someone would partition an IRA account immediately after the first SEPP distribution rather than before the plan began, but you should be OK. Your calculation documentation should show only that initial account and an account balance for that account on a specific date reasonably close to the first distribution date (eg 6/30 or 7/31 balance). Ignoring the fact that the IRS has busted a couple SEPP plans for partial transfers without providing a logical explanation, your SEPP plan would now constitute both accounts in a single plan and you could meet the annual distribution requirement with any combination of distributions from those two accounts. That means from here out neither account can receive a contribution or a non SEPP distribution. The key is that at the end of 2017 you distributed in total either the annual calculation amount or 5/12 of that amount based on the month of your first distribution. You should be OK otherwise, and while nothing is guaranteed you probably have an extremely small risk having done a partial transfer, and it could be made even smaller if you continue to take the entire distribution from only the original account. The account partition was probably done by direct non reportable transfer rather than 60 day rollover which draws less attention to the split and you will only have one 1099R to report.