You should use the 2024 Form 5329 if there are no other changes. You do not need to file a 2024 amended return. (See below for the IRS instructions.)
However, a reasonable cause waiver does not apply if missing a deadline alone is the reason. There needs to be something that was beyond your control (bank error, lost mail, hospitalization, etc.). This describes the criteria. https://www.law.cornell.edu/cfr/text/26/301.6724-1 -- In your request, be sure to address each of the requirements and explain how the facts of your case meet those requirements.
From the 2025 Form 5329 instructions:
https://www.irs.gov/pub/irs-pdf/i5329.pdf
Prior tax years. If you are filing Form 5329 for a prior year, you
must use the prior year's version of the form. If you don’t have
any other changes and haven’t previously filed a federal income
tax return for the prior year, file the prior year's version of Form
5329 by itself (discussed earlier). If you have other changes, file
Form 5329 for the prior year with Form 1040-X, Amended U.S.
Individual Income Tax Return.
Waiver of tax for reasonable cause
The IRS can waive part or all of this tax if you can show that any shortfall in the amount of
distributions was due to reasonable error and you are taking reasonable steps to remedy the shortfall. If you believe you qualify for this relief, attach a statement of explanation and file
Form 5329 as follows.
1. Complete lines 52a and 52b, and 53a and 53b, as
instructed.
2. Enter “RC” and the amount of the shortfall you want waived
in parentheses on the dotted line next to line(s) 54a and/or
54b, as applicable. Subtract this amount from the total
shortfall you figured without regard to the waiver, and enter
the result on line(s) 54a and/or 54b, as applicable.
3. Complete line 55 as instructed. You must pay any tax due
that is reported on line 55.
The IRS will review the information you provide and decide
whether to grant your request for a waiver. If your request is not
granted, the IRS will notify you regarding any additional tax you
may owe on the shortfall.
**Say "Thanks" by clicking the thumb icon in a post
**Mark the post that answers your question by clicking on "Mark as Best Answer"
