Happy-Tax
Level 4
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I'm not sure why you believe that permanent and total disability renders IRA withdrawals as nontaxable. I think you're referring to the 10%-penalty for early withdrawal (which results from Code 1 on the 1099-R). To indicate the taxpayer is not subject to the 10%-penalty, use Form 5329. Scroll down and find Line C for the input blank to remove the 10%-penalty. Also, be sure to acquaint yourself with the tax code's definition of "permanent and total disability." It's defined much more strictly than most people would assume.