2019 Missed RMD

If someone missed their RMD in 2019 but has taken it in all previous years required, is their a waiver of penalty that can be applied for? If so, what form would you use, and would you recommend paying the penalty in advance or waiting to hear back from the IRS first in case they grant the waiver?



Don’t pay the penalty. If you make up the missed 2019 RMD, you can then file Form 5329 and request a penalty waiver for “reasonable cause”. The IRS has been accepting almost any reasonable cause including that you simply forgot to complete your 2019 RMD. First make up the missed RMD and then file the 5329. You only need to complete 4 lines, but they are not intuitive, so check the IRS 5329 Inst for what to enter on those lines. If you have not filed your 2019 return yet, you can include the 2019 5329 with that return. Note that the made up RMD will be taxable in 2020, not 2019.

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