BobKamman
Level 15

Don't waste your time on a long sob story when a short one will do.  It's going to be read by an IRS clerk who gets evaluated on production, not empathy.  

The law probably requires a 5329 for each year, but I doubt IRS will ask for or expect them.  Just get in compliance for now.  Has the taxpayer been filing 1040s?  Maybe file a separate 5329 for 2022 and mention that the failure spans multiple years. 

I don't know what a Gold IRA is, either.  Gold can be held in a traditional IRA, just not with a typical trustee.