I'd say "yes you should" It's a stand-alone form that can be mailed in separately.
You've already taken the RMD that you should have withdrawn in 2017 in 2018, right? If you are requesting a waiver of the additional tax be sure to attach a well thought out a statement of explanation, with support, and attach it to the form.
The instruction state:
"Enter “RC” and the amount you want waived in parentheses on the dotted line next to line 54. Subtract this amount from the total shortfall you figured without regard to the waiver, and enter the result on line 54." So if you're asking for a compete waiver you do enter $0.
Tom Young
