I am helping a widow of a former police officer who passed away suddenly back in 2004 prior to age 60. He left behind two separate retirement accounts that were subsequently put in his widow’s name shortly after his death.

Well, time marched on. She was never advised by the two different administrators of these retirement accounts of what was required of her as it related to starting RMD’s. She assumed that any RMD would be reflective of her turning age 72 in the year 2022. What was eventually discovered was that she should have started taking RMD’s when her late husband would have turned 70 1/2 back in 2017, not when she turned age 72 in the year 2022.

Bottom line, she was required to withdraw, in 2022, historical RMD’s for years 2017, 2018, 2019, 2020, & 2021, from both retirement accounts, all in 2022. This pushed her up in a much higher tax bracket, and she is now subjected to the 50% IRS penalty for NOT taking the RMD’s at the proper time.

We have submitted pertinent paperwork to the IRS, requesting waiving of the 50% IRS penalty. Since the IRS reviews inquiries by years in different locations, apparently our total inquiry has been now shifted to several IRS offices for review. We are still hoping for a positive resolution from the IRS on the IRS penalty.

During all of this, my recent research found that the IRS has revised some of its IRS tax tables that dictate the life expectancy factor to be used when calculating an RMD. The Table I (Single Life Expectancy) (For Use by Beneficiaries), is the table used for the above mentioned RMD’s. I believe this table was revised by the IRS in January 2022. Since we had to go back retroactive to year 2017 for these historical RMD’s, should the calculation be based on the newly revised tables effective January 2022?? Or, do the revised IRS tables only apply to RMD’s for 2022 and going forward??

Unfortunately, the administrators of the retirement accounts get off from any accountability regarding their NOT doing their job. However, they always quote that they are following IRS guidelines, but rules are NOT being followed. All they say is it is you, as the account holder, that is ultimately responsible for knowing when and how to receive your RMD’s from your retirement accounts.

Again, we are hoping for a positive outcome with the IRS. If you know of any advice you can share with me to expedite resolution, it would certainly be appreciated.