My client missed taking an RMD for 2019. I informed her to take the 2019 RMD ASAP. We are preparing Form 5329 and attaching a statement requesting a waiver for the 50% penalty for not taking the RMD timely. this will be attached to the 2019 Form 1040 tax return. Both husband and wife are elderly and he has serious medical issues so the RMD was forgotten.

First, do you agree that this is a good reason for the penalty waiver?

Second, they will take the 2019 RMD now in 2020. Is this 2019 RMD to be reported along with their 2020 RMD when preparing the 2020 tax return? There is no 1099R reporting the RMD for 2019.

Thanks.