There seems to be disagreement on this subject. Section 72(t)(2)(A)(v) of the tax code says this exception applies when the distribution is:
(v)made to an employee after separation from service after attainment of age 55
However, IRS Notice 87-13 says:
A distribution to an employee from a qualified plan will be treated as within section 72(t)(2)(A)(v) if (i) it is made after the employee has separated from service for the employer maintaining the plan and (ii) such separation from service occurred during or after the calendar year in which the employee attained age 55.
