Greetings, all. Situation is: ROTH owner died 8/2007. Beneficiary (non-spouse, non-relative) only later discovered their ROTH beneficiary status in 2017, and will take a full distribution asap – if advisable. QUESTION IS: should the Beneficiary (non-spouse) take the full ROTH distribution (account worth about $70k) without delay, and provide the IRS with a 5329 Form requesting a waiver that explains the ROTH lack of awareness, and expect a waiver of penalty? and if so, should the 5329 Form be included with the 2017 1040 Form after receipt of the 1099-R from the broker as evidence of distribution? — OR — should the Beneficiary (non-spouse, non-relative) not bet on a IRS waiver acceptance and submit individual 5329s for each year that a lifetime expectancy schedule distribution could have been made, and expect to owe a 50% penalty on each un-distributed amount calculated for each year (excluding 2009)? Finally, would the Beneficiary be allowed to begin a lifetime expectancy schedule distribution series (and pay the penalty on the un-distributed years), or is it too late to distribute anything other than a full distribution now that it is later than 1 year since the ROTH owners date of death? Or in other words, can you advise, please, how to handle this situation properly and to avoid potential penalty? With thanks in advance for your reply.