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The plan has an active participant who is a greater than 5% owner and turned 70.5 in April of 2009 (DOB 11/09/1938). Since the 2009 RMD was not required this plan year will be their first minimum distribution they plan on taking. The plan would like to know if this year is technically considered the first RMD year allowing the participant until 4/1/2011 to satisfy the minimum distribution or if 2009 was the first even though it was not required meaning that this year's minimum distribution has to be made by 12/31/2010.

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