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No. A health crisis does not count as a casualty. A casualty loss occurs generally due to theft or a disaster. To claim a loss from a disaster, it must be in a federally declared disaster zone.
However, depending on what your health crises was and how much you spent on medical care, you may be able to exclude some of your 401K from the penalty.
As your walk through
Retirement topics: Exceptions to tax on early distributions
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