Clarification on medical exception for early distribution

I understand you can avoid the 10% penalty for early distributions from an IRA when using the funds to pay for unreimbursed medical expenses that exceed 10% of your AGI. My understanding is that the penalty is ONLY avoided for the specific amount of medical expenses that exceed 10% of your AGI. What if your AGI is $100k, your medical expenses are $17k and the max out-of-pocket with your health insurance is $7800? Even though the total amount paid by the IRA owner (i.e. $7800) is less than 10% of their AGI, would $7000 of their $7800 avoid the 10% penalty since their actual medical expenses are $7000 above the 10% of AGI threshold? I hope that make sense. Thanks so much!



No, only out-of-pocket expenses are considered.  Since the maximum out-of-pocket is $7,800 and 10% of AGI is $10,000, out-of-pocket medical expenses will not exceed the threshold and this penalty exception is unavailable.

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