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@msmith7305 wrote:

Lisa -

My understanding is, if you are a "qualified individual" (at any time of the year) which my client is, then ANY distributions taken from 1/1/20 through 12/31/20 are treated as corona related distributions.

My client was taking periodic IRA distributions from January to September of $5K/month ($45K).

In October he became a "qualified individual". Needed $50K more. Took it and did not take any more distributions.

1099-R shows full $95K. However, he only wants to defer the $50K over 3 years.

I am beginning to think it is an "all or nothing" deal.

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It does sound like an "all or nothing" election.  You may be able to trick the system into doing what you want it to do by creating bogus entries but I'm not finding anything in the law that permits this.