In reviewing answers to similar questions, it appears that: if the deceased passed before the end of the year, it was not the deceased who "missed" the IRA RMD but rather the IRA beneficiaries' responsibility to take the deceased's calculated RMD for the year. Fine. But, there were 10 beneficiaries and in the mess/confusion at the end of the year, the 2019 RMD was short by a small amount, which was rectified a couple of days ago. It's not clear who files the 5329 to request a waiver of the penalty: If it had not been rectified, wouldn't it be the estate that owes the penalty, so shouldn't it be the estate? Other answers suggest it's the beneficiary, but which one out of the 10? Two beneficiaries took more than they had to; three beneficiaries haven't yet taken a distribution but the RMD has been met without them so surely they don't need to file for a penalty waiver just because they didn't take anything; maybe it's filed by the beneficiary who took the last distribution that allowed the RMD to be met??
