My client is the owner/operated of a cleaning service business. He has been experiencing a down turn in business and required an infusion of cash. Client took an early distribution from his IRA in early January to keep his business solvent. Revenues contined to fall during 2020 as the corona virus spread. He nor anyone in his family or workers tested positive for the virus during 2020. Is this distribution eligible for the special exception to the 10% additional tax under 72(t) as provided for under the CARES Act?