How hard is it to get the IRS to waive the 50% penalty for a missed RMD?

[Übernerd]

Participants' pension plan failed to make timely RMDs (i.e., "age 70½" distributions). Thus, participants must pay the 50% excise tax imposed by Code § 4974. They will attach the letter (outlining the mistake and the reasonable steps being taken to correct it and begging for a waiver) to their Forms 5329. Does anybody know how tough the IRS is on such requests?

Thanks.

[Lori Friedman]

Here's what my own experience has been:

The IRS will waive the I.R.C. Sec. 4974 excise tax on a first-time failure.

Things become more difficult if a taxpayer has multiple failures in different years. The IRS is likely to take the position that there's a lack of reasonable error. It's possible, but much more problematic, to get the excise tax waived over and over again.

[Übernerd]

That makes sense. Thanks for the response.

[Guest EdShill]

Here's what my own experience has been:

The IRS will waive the I.R.C. Sec. 4974 excise tax on a first-time failure.

Things become more difficult if a taxpayer has multiple failures in different years. The IRS is likely to take the position that there's a lack of reasonable error. It's possible, but much more problematic, to get the excise tax waived over and over again.

How long does it take the IRS to act on a first-time failure?