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It's a partial termination, which would vest everyone.

Per the IRS: The IRS cannot cancel your EIN. Once an EIN has been assigned to a business entity, it becomes the permanent Federal taxpayer identification number for that entity. Regardless of whether the EIN is ever used to file Federal tax returns, the EIN is never reused or reassigned to another business entity. The EIN will still belong to the business entity and can be used at a later date, should the need arise. You (well, actually the plan sponsor) can always call the IRS to inquire that the EIN is still active: (800) 829-4933.

Guidance can be found in Notice 2020-50. In a nutshell, payments scheduled between 3/27/20 - 12/31/20 can be suspended for a year, but payments scheduled after 12/31/20 still have to be made as scheduled. There are lots of ways you can accomplish this, ranging from simple to complicated, and you don't have to use the example in the guidance.

Will spend? That is a tad extreme...

What does the document say?

I have encountered this in the past. If the reason RMDs were not made was because the recordkeeper failed to implement them, mention that and the IRS should accept it. If the real reason that the RMDs were not taken was because the owner did not want to receive them, then they are unlikely to waive the excise tax. It has to be something under the control of a third party vendor such as a recordkeeper or trustee and not because the owner did not want them or an HR employee was told not to make them for fear of having the owner cut their budget.