1) The first year distribution for a 72t can be either the full annual amount or the pro rated amount by the month. In other words, for a July inception, the amount distributed can be the full annual or half the full annual, but not a figure between those two amounts. The amount selected can be taken monthly, or in another combination. In effect, the taxpayer has until December to choose between the full annual and the pro rated figure.
2) In following full calendar years, distributions can be taken whenever the taxpayer wishes as long as the full annual amount is taken by year end. Taxpayer can switch around from year to year, eg from monthly payments to a full annual amount.
3) Yes, in the first year, an amount taken prior to starting the plan will be subject to penalty and amounts taken after a viable plan begins will be exempt from the penalty. Taxpayer will probably need a 5329 if the 1099R does not reflect this.
4) The initial plan value on which the calculations are based should not be more than 6 months prior to the inception month and must also be after any distributions taken before the plan starts.

The annual amount is therefore based on a calendar year. I don’t know that the IRS has ruled on a taxpayer that is not a CY filer.

With respect to a lump sum. A single distribution cannot be split between a 72t and a non 72t amount. The non 72t amount would have to be taken prior to the 72t amount and prior to the account balance figure used for the 72t plan. Amount withheld for taxes from a 72t distribution count as part of the 72t, so therefore the tax liability should be considered in how much is needed to fund expenses for the term of the plan.

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