"Participant A retired from Company X nearly 10 years ago. He participated in X's defined benefit plan (from which he is currently receiving a pension under a joint and 100% survivor annuity) and 401(k) plan. The pension is equal to $36,000 per year, payable in monthly installments.
During 2020, Participant A also received distributions of his remaining account under X's 401(k) plan (which had both Roth and non-Roth portions), rolled over the vast majority of it into traditional and Roth IRAs and later received distributions of the balance from both IRAs.
During 2020, A was also laid off by Company G, which is unrelated to Company X.
A would like to treat the portion of the 401(k) plan distribution which was not rolled over but otherwise subject to tax as well as the taxable portion of the traditional IRA distribution as a Coronavirus-related
distribution and pay the resulting tax over the next 3 years. A would like the pension amount received to be subject to the regular tax rules, which would subject the entire $36,000 to tax during 2020 (otherwise, A would be subject to tax on the pension during 2020 on $12,000, but would have to pay tax on $48,000 ($36,000 + $12,000) in each of 2021 and 2022).
'If more than one distribution was made during the year, you must treat all distributions for that year the same way.' Form 8915-E Instructions, page 1; IRS Notice 2020-50, Section  IRS Notice 2020-50, Section 4.B. ('All coronavirus-related distributions received in a taxable year must be treated consistently (either all distributions must be included in income over a 3-year period or all distributions must be included in income in the current year').
Seemingly inconsistent with the preceding paragraph are the following:
Instructions to Form 8915-E, page 2, 'Types of Qualified 2020 Disaster Distributions,' 'Coronavirus-related Distributions' -- 'you can generally designate any distribution (including periodic payments and required minimum distributions) from an eligible retirement plan as a coronavirus-related distribution, regardless of why the distribution was made,' provided that the aggregated distributions so designated do not exceed $100,000. Coronavirus-related distributions are permitted without regard to your need;' IRS Notice 2020-50, Section 1.C ('In general, a qualified individual is permitted to designate a distribution described in the preceding paragraph as a coronavirus-related distribution').
Reviewing the foregoing, I am inclined to conclude that the
requirement of consistency referenced in the second paragraph applies solely to determination of whether all coronavirus-related distributions (as designated by the individual) are taxed ratably over 3-years or taxed in full in the year of distribution. Therefore, A would be permitted to designate only the portion of the 401(k) account that would have been taxable but was not rolled over as well as the taxable IRA distributions as coronavirus-related distributions and not the periodic payments A was receiving from the defined benefit plan.
Does anyone have a contrary position on this?"