72(t) amortization method with recalculation

L1: 72(t) amortization method with recalculationThe IRS (in two private letter rulings: plr200432021 and plr200432024) has allowed the concerned individuals to recalculate their SEPP every year using the amortization method based upon the new principle in their IRAs. (Details here: http://www.retireearlyhomepage.com/amort2004.html ).
My question is: If I were to ask the IRS for permission to do the EXACT same thing, what do you think the chance is that they would let me? Of course I would have to invest the thousands of dollars to obtain a private letter ruling, but I”d probably be OK with paying that if I could pretty much be assured that permission would be granted.2007-06-04 18:12, By: Geoffrey, IP: [24.9.247.108]

L2: 72(t) amortization method with recalculationHello Geoffrey:
Your own PLR would cost approximately $12,000 to $15,000 depending on who you might hire including the $9,000 filing fee to the IRS. That said, I really don”t think you need to do that. In addition to the two PLRs cited; there are approximately 8 – 10 more virtually identical in nature. Thus, the issue is already solved — annual recalculation using either the amortization or annuitization mehtod is permitted provided that specific rules are followed.
My suggestion (albeit somewhat self-serving) is that you instead engage a competent professional to design the plan to insure that it meets with IRS guidelines for substantially less in fees.
TheBadger
wjstecker@wispertel.net
2007-06-04 19:28, By: TheBadger, IP: [72.42.66.113]

L2: 72(t) amortization method with recalculationThe Badger should not be so humble and modest. Even though I”m a CPA, and more knowledgement than most practitioners in the SEPP 72-T area, I would not attempt to prepare the documents needed for a favorable result in this area. Only someone experienced, having done this, or something similar, should be retained for this PROFESSIONAL service.2007-06-04 20:04, By: dlzallestaxes, IP: [151.197.33.250]

L2: 72(t) amortization method with recalculationJust to be sure…….those PLRs approve the recalculationat the inception of the 72t plan. You would not be able to convert an existing plan to recalc midterm. 2007-06-04 21:19, By: Alan S., IP: [24.116.66.98]