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New Member
posted Jun 7, 2019 5:43:27 PM

On a 1099R what qualifies as an exception for the code 2- Early distribution (except Roth)?

0 4 38160
4 Replies
New Member
Jun 7, 2019 5:43:29 PM

There are exceptions to the 10% tax penalty for early distributions:

  • Death or total and permanent disability
  • Series of substantially equal periodic payments based on life expectancy
  • Qualified first-time homebuyer distributions up to $10,000
  • Qualified higher education expenses
  • Certain medical insurance premiums paid while unemployed
  • Unreimbursed medical expenses that are more than a certain amount of your adjusted gross income
  • IRS levy
  • Certain distributions to qualified military reservists called to active duty

Once you enter the distribution information from your 1099-R form, we'll help you check for any exceptions that could reduce the tax.

Level 15
Jun 7, 2019 5:43:29 PM

A code 2 *is* an exemption.  There is no penalty with a code 2.

The payer uses a code 2 under these circumstances:

Use Code 2 only if the participant has not reached age 59½ and you know the distribution is the following.

  -  A Roth IRA conversion (an IRA converted to a Roth IRA).

   - A distribution made from a qualified retirement plan or IRA because of an IRS levy under section 6331.

   - A governmental section 457(b) plan distribution that is not subject to the
    additional 10% tax. But see Governmental section 457(b) plans, earlier, for information on distributions that may be subject to the 10% additional tax.

   - A distribution from a qualified retirement plan after separation from service in or after the year the participant has reached age 55.

  -  A distribution from a governmental defined benefit plan to a public safety employee (as defined in section 72(t)(10)(B)) after separation from service, in or after the year the employee has reached age 50.

 -   A distribution that is part of a series of substantially equal periodic payments as described in section 72(q), (t), (u), or (v).

   - A distribution that is a permissible withdrawal under an eligible automatic contribution arrangement (EACA).

   - Any other distribution subject to an exception under section 72(q), (t), (u), or (v) that is not required to be reported using Code 1, 3, or 4.

New Member
Jun 7, 2019 5:43:31 PM

does  a hardship withdrawl qualify for a code 2- early withdrawl (except Roth)?

Level 15
Jun 7, 2019 5:43:31 PM

No.  A "hardship" is a regular distribution subject to tax and early distribution penalty.     "Hardship" only allows you to even have a distribution prior to retirement.    Some employer plans do not allow hardship distributions at all.