mmclean, presumably you are referring to the incorrect answer that indicates that the early-distribution penalty cannot be avoided.
Under the QDRO, there is no statutory limitation against the alternate payee receiving multiple nonperiodic distributions from the plan. Whether or not the alternate payee is limited to taking a lump-sum distribution from the alternate payee's separate account depends on the terms of the plan. If the plan permits multiple nonperiodic distributions, there's no reason that the alternate payee couldn't apply the alternate-payee exception to multiple separate distributions from the plan. However, if any portion is rolled over to another qualified retirement account, that portion is no longer eligible for the alternate-payee exception.
