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TPA failed to pay 77 year-old participant any of her RMDs.

As I understand, the correction method would be to pay her the amount owed plus interest and then get her current for 2007.

Would I be correct in thinking that she would not get relief for reasonable cause when she has to file Form 5329? And would any liability attach to the TPA (I am sure the participant will be upset when she learns she has to pay a 50% excise tax for the past 5 1/2 years).

How have any of you handled this?

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