Client had before and after-tax money in a 401(k) that was rolled over in May 2018 to an IRA (all of the before tax money) and a Roth (all of the after tax money). There are unexpected cash needs so the client will need to withdraw from one of the accounts. For tax reasons, it makes sense to withdraw from the Roth. However, the Roth account has not been open for 5 yrs. (he’s already past 59 1/2) so I believe the 10% penalty would apply. To avoid the penalty, could the client withdraw all or part of the money (plus whatever the withdrawn amount has earned) and call it an over contribution? Is there any other way of avoiding the 10% penalty?