Yes, TurboTax makes it extremely difficult to get Form 5329 included under these circumstances where you have no Forms 1099-R to enter or you are under age 70½. If you are using the CD/download version of TurboTax you can do it in forms mode. In the online version of TurboTax you would need to do a convoluted workaround in step-by-step mode:
- Change your year of birth to something that indicates that you are over age 70½, say, 1945.
- Enter a dummy Form 1099-R for a regular IRA distribution: Box 1 and 2a = $1, code 7 in box 7 and the IRA/SEP/SIMPLE box marked and indicate that it was all RMD.
- Click the Continue button on the Your 1099-R Entries page.
- Indicate that you did not receive all of the RMD.
- Enter the amount that you should have received and the amount actually received, then click Continue.
- Enter your explanation statement
- Delete the dummy Form 1099-R. Do not click the Continue button on the Your 1099-R Entries page, otherwise TurboTax might delete the Form 5329 and you'll have to start over.
- Change your year of birth back to the correct year.
If all else fails, prepare Form 1099-R manually and include it and your explanation with your mailed tax return.
