8915E is for the 3 year spread, if youre paying tax on the entire amount on the 2020 return, all you need is the 5329

---

That might be right, but I'm not betting the farm on it just yet.  The (draft) instructions for 8915-E under "Who Must File" say:

File 2020 Form 8915-E if you received a qualified 2020 disaster distribution from an eligible retirement plan and the distribution was made in 2020 before December 31.

There's no mention of only being required to file if you're spreading the income.  My concern is that if the IRS gets a 5329 with just a generic code 12 on it and NO 8915-E they're going to want to know why you're not subject to penalty.  My plan is to include the 8915-E for folks even if they're not spreading the income over 3 years.  There is a checkbox on the form to indicate you are NOT spreading (why would they need a checkbox if the form is not required to be filed at all in that circumstance?)

So at this point let's just say I'm reluctant to simply bypass the 8915-E in this situation.

Rick