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jkharvey
I want to be sure I understand this correctly. I have a participant who terminated in 2008 at age 74. This was not a 5% owner so the RBD is not until 4/1/2009. Since the RMD due 4/1/2009 was actually for 2008, the amount is still due but the 2009 distribution is not. Is that correct?
J Simmons
That's my understanding, too.
Kevin C
Notice 2009-9 also agrees with you.

http://www.irs.gov/pub/irs-drop/n-09-09.pdf
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