72(t)

[Dobber]

Can the initial 72(t) SEPP payment be prorated?

Or regardless (when during the year) it's taken is the IRA owner required to distribute what amounts to the full year payment?

What guidance has the IRS issued?

All assistance is appreciated

[bito'money]

My understanding is that the 3 methods for determining the SEPP amount that would meet the 72(t) exception all require you to determine the amount required to be withdrawn each year on an annual basis without proration.  See IRS Notice 2022-6. 

If you think about it, you don't get to prorate an RMD amount under the RMD rules because you started the payment later in the year. IRS only cares that you include the amount of the payment in gross income during the specified calendar year and they don't care when you start your distribution. Same principle would apply here.