Part IX of Form 5329 is titled "Additional Tax on Excess Accumulation in Qualified Retirement Plans (Including IRAs)." The instructions for lines 52 and 53 apply to excess accumulations in either of these types of accounts, they do not make any distinction. After the paragraphs that describe excess accumulations in non-Roth IRAs are the paragraphs that describe excess accumulations in qualified retirement plans (other than IRAs).
