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Form 5329, when one believes they have reasonable cause to be entitled for a waiver of the penalty, can they file form 5329 prior to filing the 1040? How to complete the 1040 form 5329 part IX, before an answer from the IRS, pay the penalty or leave blank line 55?

Penalty Individual Retirement Accounts (IRAs)
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John Stancil
The IRS does not respond specifically to a 5329 unless you have taken the waiver of penalty in error. Line 55 applies only if you did not take the required minimum distribution (RMD) and are paying the penalty for not doing so. That should be fairly straight forward, as the RMD is given on your Form 5498. Part I , line 2 is where you enter the amount and reason for the penalty waiver. If you are fining a return, you should send it in with your return, not separately.
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