It's been noted that TurboTax Online make it difficult to attach Form 5329 in this scenario.
Maybe they fixed that.
If you e-File without Form 5329 because TurboTax Online won't produce it,
and wush to request a full waiver of the penalty, you can attach Form 5329 to 1040-X and put your explanation in Part III.
The proper way to file Form 5329 is attached to Form 1040-X.
Form 5329 can be mailed by itself only when you are otherwise not required to file a tax return.
After you e-File,
get Form 1040-X from IRS website and mail it in with your 5329 which you can also get in fillable PDF.
Note: since you are not changing any dollar amounts on your amended tax return, you can leave all the lines 1-23 EMPTY.
Part III explanation: will explain to the IRS why you missed the RMD, what action you took that they should waive your penalty. Include dates and amounts to show timely action on your part. This is required if you request a waiver.
When mailing 1040-X, do not include your old 1040 nor your revised 1040 because the Form 1040-X reflects any changes there and becomes your new tax return.
@Rajendra
