Excellent discussion, thank you.
Here is the link to the blog: https://www.kitces.com/blog/fix-rmd-missed-forgotten-miscalculated-corrective-action-form-5329-penal.... I'm referring to the very last section entitled, "Beneficiaries should take corrective action..." BUT, re-reading it with your comments in mind, I can see that section might be only referring to distributions the deceased was required to have made before death (e.g., for a prior year).
Looking at the penultimate section, entitled, "Post-Death RMD shortfalls..." I don't actually see any discussion related to taking the decedent's post-death remaining RMD but rather only a discussion of non-spouse beneficiaries needing to take their RMD by the end of the year following the year of death.
I'll take the approach discussed in this thread, and keep my fingers crossed that the beneficiary in question actually files what I provide, including the letter of explanation; certainly, it will be more motivation if it's not the estate who would owe the penalty. I am not certain which beneficiary would end up owing the penalty if this one doesn't file the 5329, as 3 beneficiaries took no distribution so it seems unfair for the penalty to land on the one beneficiary who finally made up the remaining RMD this week. BUT, as you observe, it is likely a rhetorical question.
It has been a pleasure to talk with you. Thank you for taking the time.
