RMD question

[BG5150]

I have someone (non-owner) who needs to take an RMD for 2010. She is 74 and separated from service in September 2010. Her RMD is slated to be about $600.

However, earlier in the year, she took a hardship distribution for $1,000.

Does she still need to take the RMD?

I would tend to think not because the hardship:

1. was paid to her (not rolled over)

2. wasn't eligible for rollover

3. taxes were withheld

4. it was for more than the RMD

5. tax form will still be code '7'

Your thoughts are appreciated.

[masteff]

I agree. Reg 1.401(a)(9)-5 Q&A-9