Apply Tax Planning Ideas to Improve Retirement Distributions

The choice of retirement plan beneficiary can affect not only who receives plan benefits, but also the timing of the benefit distributions.

Many individuals have a substantial portion of their wealth concentrated in retirement plans. An individual's total benefits under all retirement plans may be worth millions of dollars. Planning for the distribution of retirement benefits requires the coordination and consideration of the income, estate, and gift tax consequences for an individual during his lifetime and at death. After gaining a proper understanding of these complex rules, tax advisors can offer their clients constructive solutions to the tax problems potentially created by these benefits.

Penalties for noncompliance

The Code imposes penalties both if distributions are delayed too long or if distributions are taken too soon.

Late withdrawals. Because participants in qualified retirement plans and owners of IRAs (hereinafter qualified retirement plans and IRAs are referred to collectively as "plans.") are not taxed on the funds until they actually receive payments from the plan, the law does not allow the funds to be kept in the plan indefinitely. Eventually, they must be withdrawn. If the participant does not withdraw at least the minimum amounts required by law, a 50% excise (penalty) tax is imposed on the amounts that should have been withdrawn but were not. ¹

Example. Alan is required to withdraw $20,000 from his IRA by 12/31/03. He withdraws only $15,000, however, during 2003. As a result, Alan will incur a $2,500 penalty for failing to withdraw the full $20,000 ($20,000 - $15,000 = $5,000 withdrawal shortfall — 50% = $2,500).

The withdrawal requirements differ, depending on whether the distributions are being made to the participant or the beneficiary of a deceased participant's plan. These rules are discussed below.

Early withdrawals. Generally, a participant may not withdraw funds from a plan until he or she reaches age 59 1/2. If the participant makes withdrawals before then, a 10% excise tax is generally imposed in addition to the income tax on the withdrawn amount. ² The following are exceptions to this rule:

(1) If the participant becomes disabled prior to reaching age 59 1/2, amounts withdrawn as a result of the disability are not subject to the 10% excise tax.
(2) If the participant dies prior to reaching age 59 1/2, the assets in the plan may be distributed to the beneficiary or to the participant's estate without either having to pay the 10% excise tax.
(3) If the participant receives distributions from the plan for medical, educational, first-time home buying, and certain other exceptions enumerated in Sections 72(t)(2)(B) through (F).
(4) If the participant receives distributions from the plan as a part of a series of "substantially equal periodic payments" (i.e., annuity payments).

Distributions that fall into one of the statutory exceptions are not subject to the 10% excise tax.

Substantially equal periodic payments. To qualify for the waiver of the 10% penalty in item 4, above, the distributions must satisfy each of the following requirements:

• The distributions must be made at least annually.
• They must be calculated using the life expectancy of the taxpayer (or a joint life expectancy).
• They must include the use of a reasonable interest rate.
• The taxpayer must continue the distribution plan without change for at least five consecutive years and until the taxpayer reaches age 59 1/2 (if that is longer than five years). ³

Example. Betty begins receiving distributions from her qualified retirement plan when she is age 52. Such payments must continue until age 59 1/2. If Betty's distributions began at age 58, the distributions would need to continue through age 63 (i.e., for five years) to avoid the 10% penalty.

Any modifications made to a distribution schedule for substantially equal periodic payments, either changing the distribution amounts (e.g., by changing assumptions, or methods of calculation) or violating the five-year and age 59 1/2 requirement, cause a retroactive application of the 10% tax. The taxpayer also would pay interest on the retroactive penalty. Interest payments are calculated based on the deferral period obtained by the taxpayer in delaying the payment of the penalty. ⁴

For example, in 2000, a 52-year-old IRA owner began receiving level-payment distributions from an IRA. The annual distribution amount is $24,000. In 2004, the IRA owner does not take the required distribution. The early withdrawal penalty is $9,600 ($24,000 — 4 years — 10%), plus any interest due on the penalty.

On the completion of the five-year and age 59 1/2 requirement, the taxpayer may withdraw any or all of the remaining balance without exposure to the 10% penalty.

Minimum distribution rule basics

Both lifetime and post-death distributions are subject to the "minimum distribution rules," which dictate:

(1) The time when payments from the plan must begin.
(2) The payout period over which distributions must be made.
(3) How much must be distributed in a given year.

The minimum distribution rules reflect the congressional view that retirement benefits should be used for a participant's lifetime needs after retirement, rather than as a death benefit for the participant's beneficiaries. Final regulations issued in 2002 greatly simplified the original rules contained in proposed regulations issued in 1987. ⁵

Required beginning date. The plan participant must begin to withdraw funds from the plan no later than the required beginning date (RBD). The RBD is April 1 of the year following the later of (1) the year in which the participant reaches age 70 1/2, or (2) for employer-sponsored retirement plans, the year in which the participant retires from the employer maintaining the plan (unless the participant owns a 5% or greater interest in the employer). ⁶ The participant must thereafter take a distribution by December 31 of each year. Although a retired participant need not take a distribution until April 1 of the year following the year he or she reaches age 70 1/2, if he or she chooses to wait until that following year to take that first distribution, then he or she must take two distributions in that first year following the year he or she reaches age 70 1/2: one by April 1 and one by December 31.

Example. Claudia will reach age 70 1/2 on 6/1/06. Her first minimum distribution year is 2006, and Claudia's minimum required distribution for 2006 (her 70 1/2 year) must be taken no later than 4/1/07. Claudia's minimum distribution for 2007 (the first year after her 70 1/2 year) must be taken no later than 12/31/07.

Payout period under prior rules. Under the "old" rules (i.e., the 1987 proposed regulations), the participant had to choose to take distributions in a lump sum or in installments over either:

(1) His or her own life expectancy.
(2) The joint life expectancy of himself or herself and his or her spouse.
(3) The joint life expectancy of himself or herself and some other designated non-spouse beneficiary (who, under the "minimum distribution incidental benefit rule," was deemed to be no more than ten years younger than the participant, despite the actual age of the beneficiary).

Choosing to spread distributions over a joint life expectancy as opposed to a single life expectancy provided the benefit of increasing the number of installments, thus decreasing the minimum required to be withdrawn each year and maximizing income tax deferral.

Example. David, a 70-year-old participant, elects to have his account balance distributed in installments over his single life expectancy. Using the expected return multiples in Table V of Reg. 1.72-9, David would be permitted to spread distributions over a 16-year period (i.e., the life expectancy of a 70-year-old person). If David has a wife who is two years younger, he could instead elected to have his account balance distributed in installments over his spouse's and his joint life expectancies; using the expected return multiples in Table VI of Reg. 1.72-9, he would have been permitted to spread the distributions over a 21.5 year period.

New minimum distribution rules

The minimum distribution rules were revised in a way that fosters simplification and potentially longer payout periods.

Lifetime required distributions. In general, the "minimum required distribution" (MRD) is calculated to fully distribute a participant's interest in the plan over a period not exceeding the combined life expectancies of the participant and a "fictional" person ten years younger than the participant. The final regulations provide a uniform distribution period for all plan participants of the same age, unless the participant's spouse is more than ten years younger than the participant. ⁷ Where a participant has a spouse that is more than ten years younger than the participant and the spouse is the sole beneficiary, the participant may take distributions over the joint life expectancies of the participant and spouse. This results in a smaller required distribution.

From now on, almost all individuals will use one "Uniform Lifetime Table" for calculating lifetime required distributions, regardless of who is named as beneficiary (or if there is no beneficiary designated), thus eliminating the need to elect a method of determining life expectancy. The "Uniform Lifetime Table" appears in Exhibit 1.

Post-death required distributions. The "applicable distribution period" is the life expectancy of the designated beneficiary who actually inherits the benefits when the participant dies (not, as previously, the beneficiary who was named as of the "date of death or RBD, whichever occurred first"). ⁸ This single life expectancy table appears in Exhibit 2. Also, the identity of the post-death designated beneficiary is not finalized until September 30 of the year following the year of the participant's death. Prior to that time, accounts can be separated, disclaimed, or paid out in full to eliminate or segregate the interests of certain "designated beneficiaries" to extend the time period over which the benefits may be distributed.

The final regulations clarify that in order to be a "designated beneficiary," the individual must be someone named by the participant in a beneficiary designation form or under the participant's plan as of the participant's death. Therefore, a person who acquires the right to receive the benefit under state law, for instance, as a beneficiary of the decedent's estate, is not treated as a designated beneficiary for purposes of the required minimum distribution rules. A trust with (only) ascertainable human beneficiaries may also be a "designated beneficiary."

Lifetime distributions

Minimum required distributions are determined by dividing the participant's account balance (revalued annually) by a life expectancy factor (called the "divisor"). Under the final regulations, there are only two methods of determining the "divisor":

(1) A special method if the beneficiary is the participant's spouse and is more than ten years younger than the participant.
(2) The method used by everyone else.

The divisor is redetermined annually (i.e., it is not a fixed term from the outset). Thus, a participant may determine his or her MRD for each year based on nothing more than his or her current age and his account balance as of the end of the prior year.

If the participant's spouse/beneficiary is more than ten years younger than the participant, the life expectancy factor is determined based on the participant's and spouse's ages on their birthdays using the Joint and Last Survivor Table under Reg. 1.401(a)(9)-9, A-3. The applicable distribution period is the joint life expectancy of the participant and spouse using the participant's and spouse's attained ages as of the participant's and the spouse's birthdays in the distribution calendar year. (Note that this formulation mandates recalculation of the participant's and spouse's life expectancies.)

Example. Eli is an IRA owner who attains age 70 1/2 in the second half of 2003. He designates his spouse as the sole beneficiary under the IRA, She is 20 years younger than Eli. He elects to take his first distribution in 2003. The balance in the IRA as of 12/31/02 was $1 million. Eli's minimum required distribution for the year 2003 is $29,411.76 calculated as follows:

The life expectancy (except when the spouse is more than ten years younger) is determined by using the "Uniform Table." To use the table, follow these steps:

(1) Take the participant's age on his or her birthday in the year in which he or she is to take the distribution.
(2) Divide the prior year end account balance by the applicable divisor in the "Uniform Lifetime Table."

Unlike under the old rules, there is no disadvantage to the participant, during the participant's lifetime, of naming a charity as beneficiary of an IRA (i.e., it will not accelerate annual distributions).

Example. Fran attains age 70 1/2 in the second half of 2003. She designates her spouse as the sole beneficiary under her IRA. (Her spouse is not more than ten years younger than she.) Fran elects to take her first distribution from the IRA in 2003. The IRA balance as of 12/31/02 is $1 million. The participant's minimum required distribution for the 2003 is $36,496 ($1 million divided by a divisor of 27.4).

Lifetime planning opportunities

Beneficiary designations are still important, but participants now have more flexibility to change them before or after the participant's RBD. (Under the "old rules" the beneficiary designation became irrevocable after the RBD.) Participants may want to review their existing beneficiary designations, since they can now be changed without running the risk of accelerating their lifetime distributions.

Shortest life expectancy used if plan not divided. The participant may choose to name multiple beneficiaries of the plan, such as his or her children or grandchildren. If the plan is not divided into separate accounts for each beneficiary, but rather kept as one account for the benefit of all the beneficiaries, the payout period is calculated by using the life expectancy of the beneficiary with the shortest life expectancy (i.e., the oldest beneficiary of the group). ⁹

Individual life expectancy used if plan divided. If the plan is divided into a separate account for each beneficiary rather than being kept as one account, each beneficiary may use his or her own life expectancy for his or her share of the benefits. Each account would have its own minimum distribution amount calculated separately each year based on the life expectancy of the beneficiary who received that portion of the benefits.

All beneficiaries must be individuals. If multiple beneficiaries are named, all of them must be individuals, as opposed to when only one beneficiary is named. If multiple beneficiaries are named and any amount is payable to a non-individual (e.g., a charity), all of the benefits will be required to be withdrawn by December 31 of the fifth year following the participant's death.

Post-death distributions

The determination of the "designated beneficiary" will now be made on September 30 of the year following the year of the participant's death. ¹⁰ This does not mean that new beneficiaries can be named post mortem. Rather, it means that the rules require looking at who actually stands to receive the balance of the plan on September 30 of the year after the participant's death. If a beneficiary has made a disclaimer in the interim, or has been paid 100% of the benefit due him, her, or it (and this particular scenario is important where a charity is a partial beneficiary, because the charity may be paid out before September 30 of the year following the participant's death, so there is no longer a non-individual beneficiary at that point), that particular beneficiary will no longer be considered for purposes of determining the MRD.

Death before RBD. Under the final regulations, whenever there is a designated beneficiary, the default rule is the life expectancy rule. This permits the benefit to be paid out over the beneficiary's life expectancy, determined in the year following the participant's death and reduced by one for each year that elapses thereafter, as long as the payments commence by the end of the year following the year of death. If no designated beneficiary is named (including if the beneficiary is the participant's estate), the IRA benefit must be paid out by the end of the fifth year following the year of death. ¹¹

Surviving spouse as beneficiary. If the surviving spouse is the sole beneficiary, the applicable distribution period during the spouse's lifetime is the spouse's life expectancy, redetermined each year. If the spouse dies after he or she is required to take distributions, the applicable distribution period is the spouse's life expectancy in the year of his or her death, reduced by one year for each year that elapses thereafter. If the spouse dies prior to the date he or she is required to take distributions, the benefits must be distributed by the end of the fifth year following the spouse's death or over the life expectancy of the spouse's designated beneficiary. The spouse can wait until the later of the year in which the participant would have reached age 70 1/2 or the year following the year of the participant's death to begin receiving minimum distributions. Of course, a spouse may always roll over the inherited IRA into his or her own IRA.

If there is just one nonspouse beneficiary If someone other than the spouse is the only beneficiary, that beneficiary must take required distributions either (1) under the five-year rule (if the beneficiary is not a designated beneficiary) or (2) over the beneficiary's life expectancy (determined based on the beneficiary's age on the beneficiary's birthday in the year immediately following the year in which the participant died) beginning no later than December 31 of the year after the year in which the participant died (if the beneficiary is a designated beneficiary).

If there are multiple beneficiaries. The beneficiaries must take distributions either (1) under the five-year rule (if the beneficiary is not a designated beneficiary) or (2) over the oldest beneficiary's life expectancy (determined based on his or her age on his or her birthday in the year immediately following the year in which the participant died) beginning no later than December 31 of the year after the year in which the participant died (if the beneficiary is a designated beneficiary).

If there are multiple beneficiaries, and one beneficiary is not an individual or, if there are multiple beneficiaries and any of them is not an individual. In these situations, there is "no designated beneficiary," and all benefits have to be distributed under the five-year rule (at least by December 31 of the year that contains the fifth anniversary of the date of death). ¹²

Death after RBD. If death occurs after the RBD, the applicable distribution period under the final regulations is the longer of:

(1) The life expectancy of the participant's designated beneficiary, determined in the year following the participant's death.
(2) The remaining life expectancy of the participant. (If there is no designated beneficiary, the remaining life expectancy of the participant is used.)

These life expectancies are determined as of the year of the participant's death, in each case reduced by one for each year that elapses thereafter. If the spouse is the sole beneficiary, the applicable distribution period during the spouse's lifetime is the spouse's life expectancy redetermined each year. After the spouse dies, the applicable distribution period is the spouse's remaining life expectancy in the year of his or her death, reduced by one year for each year that elapses thereafter.

If the surviving spouse is the sole beneficiary. The method is the same as that described above, where the participant dies before the RBD and the surviving spouse outlives the RBD.

If there is just one non-spouse beneficiary or if there are multiple beneficiaries. The method is the same as described above, in those same situations in the case of death before the RBD.

Example. The participant was born on 2/1/18. The participant designated his or her three children as the beneficiaries of the IRA. The oldest beneficiary was born on 6/1/42. The balance in the participant's IRA as of 12/31/02 is $1 million. The IRA's value increases at the rate of 10% per annum.

MRD for the year of death. The participant dies in 2003 without taking his or her minimum distributions for 2003. The minimum distribution for the year in which the participant died is based on the deceased participant's required distribution schedule under the "Uniform Table" which is $67,568 calculated as follows:

 

IRA balance as of the end of 2002	$1,000,000
Divisor using the "Uniform Table" (based on the participant's age on the year 2003 birthday (85)	14.8
$1,000,000/14.8	$67,568

Because the deceased participant had not yet taken the minimum distribution for the year of the participant's death, the beneficiaries must take out that distribution before the end of 2003 (i.e., using the schedule the decedent was using to calculate distributions).

MRD after participant's death. Because there are multiple beneficiaries who are all individuals, and no separate accounts were established, the beneficiaries must take required distributions over the oldest beneficiary's life expectancy based on his or her age on his or her birthday in 2004 (the year after the participant died) beginning no later than 12/31/04 (the year after the year the participant died). Therefore, the beneficiaries' minimum required distribution for the year 2004 is $45,346 calculated as follows:

 

IRA balance as of the end of 2001nn	$1,020,290
Divisor using the Single Life Table under Reg. 1.401(a)(9)-9, Q&A-1, beneficiary's age on the year 2003 birthday (62)	23.5nn
$1,020,290/23.5nn	$43,416.59

If there are multiple beneficiaries, and one beneficiary is not an individual or, if there are multiple beneficiaries, and any of them is not an individual. There is no "designated beneficiary." The "applicable distribution period" will then be the participant's life expectancy, determined using the IRS's single life expectancy table, based on the participant's age on his birthday in the year of his death, and reduced by one year in each year after. This method is one of the only times that the MRD is affected by the timing of the participant's death.

These rules apply separately if the IRA has been successfully divided into separate shares. The final regulations appear to make this more difficult to do post mortem (which is contrary to the approach the IRS had been taking in its letter rulings ¹³).

 

Planning issues

Various planning opportunities arise, depending on the identity of the beneficiary.

Spouse as beneficiary. The Retirement Equity Act of 1984 requires spousal consent to any beneficiary designation under a qualified retirement plan that does not name him or her as the primary beneficiary of some or all of the plan benefits and to any form of payment during the participant's lifetime other than a qualified joint and survivor annuity. This requirement applies to all pension plans and most profit sharing plans, but not to IRAs. Thus, absent the spouse's nnconsent to the contrary, the participant must name his or her spouse as beneficiary of a qualified retirement plan, but not IRAs. (The plan may allow for the deferral of these spousal rights if the participant and the spouse have been married for less than a year.)

Income tax advantages of rollover. If permitted under the plan, on the death of the plan participant, the surviving spouse may roll the inherited plan benefits over into his or her own IRA, which may be an existing IRA or an IRA established for the purpose of receiving the inherited plan benefits. The surviving spouse may then name his or her own designated beneficiary for the IRA and commence distributions at his or her own RBD over the joint life expectancy of himself or herself and his or her designated beneficiary. The rollover thus provides a powerful tool for maximizing income tax deferral.

Any minimum distribution requirements that were in effect prior to the participant's death cease once the benefits have been rolled over, and those requirements do not apply again until the surviving spouse reaches his or her own RBD. The rollover option is available to only the participant's spouse.

Disadvantage of rollover if spouse is under age 59 ½. If the surviving spouse is under age 59 1/2, he or she is entitled to withdraw from the deceased participant's plan without penalty. However, if the surviving spouse rolls the inherited benefits over into his or her own IRA, he or she is treated as the owner of those benefits. Thus, any amounts withdrawn after the rollover are subject to the 10% penalty tax imposed on withdrawals prior to age 59 1/2, unless he or she falls within an exception to this rule.

Charities as beneficiaries. A participant who desires to benefit a charity at his or her death can achieve a significant tax advantage by using retirement benefits to satisfy the bequest. Charities are exempt from income taxes, and therefore can receive the entire death benefit free of income tax.

If a plan participant desires to name a charity as beneficiary of all of the plan's benefits, the participant may simply name the charity as beneficiary. If a charity will receive only part of the benefits, however, a separate account should be established exclusively for the charity's portion. The rationale for this is that where several beneficiaries are named, all of them must be individuals in order to qualify for taking periodic distributions over the life expectancy of a beneficiary (or the beneficiary and the participant, if death is after the RBD).

Estate taxes. It is critical to remember that although an IRA may be distributed over the life expectancy of individual designated beneficiaries or of a trust beneficiary, the estate taxes on the IRA are still generally due within nine months of the participant's death. Ideally, the estate tax attributable to the IRA should be paid from some source other than the IRA in order to avoid accelerating income taxes on the IRA.

Descendants as beneficiaries. The participant may choose to name multiple beneficiaries of the plan, such as his or her children or grandchildren. If the plan is not divided into separate accounts for each beneficiary, but rather kept as one account for the benefit of all the beneficiaries, the payout period is calculated by using the life expectancy of the beneficiary with the shortest life expectancy (i.e., the oldest beneficiary of the group).

If, however, the retirement plan is divided into a separate account for each beneficiary rather than being kept as one account, each beneficiary may use his or her own life expectancy for his or her share of the benefits. Each account would have its own minimum distribution amount calculated separately each year based on the life expectancy of the beneficiary who received that portion of the benefits.

Separate accounts with different beneficiaries may be established at any time, either before or after the participant's RBD, but they must be established no later than the end of the year following the year of the participant's death for purposes of determining the applicable distribution period. If the separate accounts are established after the beneficiary determination date (September 30), the applicable distribution period in that year will be based on the life expectancy of the oldest beneficiary as of the beneficiary determination date. In the following year, the applicable distribution period for each separate account is based on the life expectancy of the oldest beneficiary of such account.

If the separate accounts are established on or before the determination date (September 30) and after the calendar year in which the participant died, the applicable distribution period for each separate account should be based on the life expectancy of the oldest beneficiary of such account. The final regulations, however, do not address this specifically.

Trusts as beneficiaries. A trust can be named as a beneficiary of the plan. However, for the trust to be a designated beneficiary for purposes of the minimum distribution rules, and to avoid having to take all distributions within five years of the participant's death, the trust must satisfy certain requirements:

 

• The trust must be valid under state law, be irrevocable, or become irrevocable on the plan participant's death.
• All beneficiaries of the trust must be individuals (as opposed to estates, corporations, or charities).
• The beneficiaries of the trust must be identifiable.
• A copy of the trust instrument must be provided to the plan administrator or IRA custodian or trustee by the end of the year following the year of the plan participant's death.

Assuming these requirements can be satisfied, the life expectancy of the oldest trust beneficiary is used for purposes of the minimum distribution rules. Generally, the deadline for providing documentation of the underlying beneficiaries of a trust to the plan administrator or IRA custodian is October 31 of the year following the year of the participant's death.

Year of death distributions and rollovers. The final regulations provide that if a participant dies during the year, there is a required minimum distribution for the year of death if the participant is in pay status. The final regulations assume that the participant was alive for the entire year (even if the participant dies on January 1) and the minimum distribution must be made for that year. The final regulations further provide that such distribution must go to the participant's beneficiary and not the decedent's estate.

The final regulations clarify that if a participant dies during the year, the surviving spouse is required to take a required minimum distribution attributable to the deceased participant for the year of death. Although the surviving spouse can elect a rollover, if the spouse does roll over all the money, there is a potential excise tax problem. To avoid this, the rollover should be minus the required minimum distribution attributable to the deceased participant in the year of death. Under the 2001 proposed regulations, the spouse could effect the rollover only if the spouse first took the distribution.

 

Income in respect of a decedent

Death benefits under qualified plans and IRAs are income in respect of a decedent (IRD), which means income that is generated by an individual during life but not subject to income taxes until after death. IRD is taxed to the recipient (the estate, trust, or individual beneficiary) when it is received.

If IRD is transferred or assigned by the recipient (e.g., an estate) to satisfy a pecuniary bequest (such as a pecuniary marital or credit shelter formula), immediate recognition of the income by the recipient may result. Therefore, if possible, retirement benefits should not be used to fund a pecuniary bequest under a will or revocable trust.

The recipient of the IRD is entitled to an income tax deduction for the federal estate tax attributable to the IRD. Note that this deduction only partially offsets the "double tax" burden.

 

Exhibit 1.The "Uniform Lifetime Table"

(for calculating lifetime required distributions)

 

Age	Applicable Divisor	Age	Applicable Divisor	Age	Applicable Divisor
70	27.4	86	14.1	102	5.5
71	26.5	87	13.4	103	5.2
72	25.6	88	12.7	104	4.9
73	24.7	89	12.0	105	4.5
74	23.8	90	11.4	106	4.2
75	22.9	91	10.8	107	3.9
76	22.0	92	10.2	108	3.7
77	21.2	93	9.6	109	3.4
78	20.3	94	9.1	110	3.1
79	19.5	95	8.6	111	2.9
80	18.7	96	8.1	112	2.6
81	17.9	97	7.6	113	2.4
82	17.1	98	7.1	114	2.1
83	16.3	99	6.7	115	1.9
84	15.5	100	6.3
85	14.8	101	5.9

Exhibit 2.Single life expectancy table

(for calculating designated beneficiary's distributions)

 

Age	Applicable Divisor	Age	Applicable Divisor
1	82.4	56	28.7
2	81.6	57	27.9
3	80.6	58	27.0
4	79.7	59	26.1
5	78.7	60	25.2
6	77.7	61	24.4
7	76.7	62	23.5
8	74.8	63	22.7
9	73.8	64	21.8
10	72.8	65	21.0
11	71.8	66	20.2
12	70.8	67	19.4
13	69.9	68	18.6
14	68.9	69	17.8
15	67.9	70	17.0
16	66.9	71	16.3
17	66.0	72	15.5
18	65.0	73	14.8
19	64.0	74	14.1
20	63.0	75	13.4
21	62.1	76	12.7
22	61.1	77	12.1
23	60.1	78	11.4
24	59.1	79	10.8
25	58.2	80	10.2
26	57.2	81	9.7
27	56.2	82	9.1
28	55.3	83	8.6
29	54.3	84	8.1
30	53.3	85	7.6
31	52.4	86	7.1
32	51.4	87	6.7
33	50.4	88	6.3
34	49.4	89	5.9
35	48.5	90	5.5
36	47.5	91	5.2
37	46.5	92	4.9
38	45.6	93	4.6
39	44.6	94	4.3
40	43.6	95	4.1
41	42.7	96	3.8
42	41.7	97	3.6
43	40.7	98	3.4
44	39.8	99	3.1
45	38.8	100	2.9
46	37.9	101	2.7
47	37.0	102	2.5
48	36.0	103	2.3
49	35.1	104	2.1
50	34.2	105	1.9
51	33.3	106	1.7
52	32.3	107	1.5
53	31.4	108	1.4
54	30.5	109	1.2
55	29.6	110	1.1
			111+	1.0

1 Section 4974(a).
2 Section 72(t).
3 Sections 72(t)(2)(A)(iv) and (4).
4 Section 72(t)(4).
5 See Esterces, "Final Regs. Give Dramatic Benefits to Beneficiaries of Inherited IRAs," 69 PTS 4 (July 2002).
6 Section 401(a)(9)(C).
7 Reg. 1.401(a)(9)-5, Q&A-4.
nn8 Reg. 1.401(a)(9)-5, Q&A-5.
9 Reg. 1.401(a)(9)-5, Q&A-7.
10 Reg. 1.401(a)(9)-4, Q&A-4.
11 Reg. 1.401(a)(9)-3, Q&A-1.
12 Reg. 1.401(a)(9)-4, Q&A-3.
13 See, e.g., Ltr. Rul. 9809059.