2021 IRMAA And Decrease In 2020 MAGI From 2019 MAGI

Submitted by fairira on Tue, 2020-12-15 06:32

One’s 2019 MAGI was enough to barely create an IRMAA for 2021.

Because of taking less in TIRA distributions in 2020 than what the RMD would have been, the 2020 MAGI will be low enough to preclude IRMAA in 2022. A decrease in one’s pension benefits is a stated basis for appeal of an IRMAA using Form SSA-44. Is there a similar basis for appealing the IRMAA determination for 2021 when the MAGI decrease is because of a decrease in one’s TIRA distributions?

Thank you for your help.



Submitted by Alan - IRA critic on Tue, 2020-12-15 14:36

If your IRMAA MAGI is low enough to avoid a surcharge for 2022, you should automatically avoid it and should not have to appeal.

Submitted by David Mertz on Tue, 2020-12-15 15:42

I think that the question is in regard to appealing the 2021 IRMAA based on the reduction in 2020 income due to not taking the TIRA distribution that would have been the 2020.  Does voluntarily not taking the TIRA distribution in 2020 that otherwise would have been required constitute basis for an appeal of the 2021 IRMAA originally based on 2019 MAGI?

Submitted by fairira on Thu, 2020-12-17 07:37

Yes, DMx, thank you for clarifying my question which you stated quite well.  I’ll try to restate it again:  Since a decrease in one’s 2020 pension benefits is a stated basis for appeal (using Form SSA-44) of one’s IRMAA for 2021, is there a similar basis for appeal of the IRMAA determination for 2021 (based on the 2019 MAGI) by using one’s IRMAA-proof 2020 MAGI which is low because of the voluntary, low amount of 2020 TIRA distribution?

Submitted by Alan - IRA critic on Thu, 2020-12-17 14:44

  • I certainly doubt that the 2020 reduction would be allowed because it is entirely voluntary. The IRA is still there to distribute the would be 2020 RMD amount or more if desired. Suppose you distributed more than your RMD in 2018 and in 2019 you dropped back to your actual RMD, or you took your actual RMD in 2018, then suffered large investment losses in your IRA that year which substantially reduced your 2019 RMD – neither of those reduced 2019 distribution reduction examples were mandatory, and are variations of the stated voluntary situation.
  • If for some reason your IRA was composed of CDs with substantial early withdrawal penalties that would only be waived for RMDs, or an IRA annuity with surrender charges that would only be waived for RMDs, these situation would produce a required loss of value due to the RMD waiver, and could possibly be considered loss of income producing property due to disease (pandemic leading to RMD waiver), but even this situation would be a long shot.

Submitted by fairira on Fri, 2020-12-18 21:12

Thank you and many thanks for the unpaid time and help you have quickly provided for many years now.My best holiday wishes.

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