Usually, plans permit a distribution of rollover amounts at any time. The distribution would be subject to tax so the 20% withholding is not necessarily a bad thing and, yes, unless an exception applies that distribution would be subject to the 10% premature withdrawal tax. Peter seems to have covered the possible exceptions. Don't think the 72t2Aiii exception would apply because it would cover the client's disability and not the father's, so the medical expense exception seems like the best possibility. If the father is indeed disabled, it seems like there would be a very good chance he would be a dependent of your client's. The father may qualify for a dependent if his gross income doesn't exceed $5,200 (2025) and the support the client provides exceeds the father's income. Social Security doesn't generally count towards the father's gross income for this purpose but income generally does. The client can count food, medical bills, living expenses as well as the fmv of the portion of the home the father occupies as part of the support he provides his father. Medically necessary home improvements, e.g., ramps, wider doorways, bathroom modifications, etc. can be deductible under 213 if directly related to the medical condition and not just for general home improvement. This should all be properly documented with letters from doctors, contractors, etc. I believe that only the portion of the medically necessary expenses in excess 7.5% of the client's AGI would be able to escape the 10% tax but you should confirm. Like Peter says, he should have his CPA/lawyer/financial advisor look at all of this.