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And I understand that the penalty is the same whether it's for an IRA or 401k but that's not my situation. If that were the case, the question would work. However, I don't have a shortfall on both accounts, only on one. I have withdrawn more than the RMD on the 401k and apparently that can't be used to offset my shortfall on the IRA. But if I combine both RMDs in that question, it looks like the excess withdrawal from the 401k is offsetting the shortfall on the IRA.