Change of custodian- busted 72T

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L1: Change of custodian- busted 72TI have an IRA taking distributions under 72T. In 2007 there was a change of custodian. The distributions from the new custodian were requested on a timely basis. However, the first one was delayed one month due to compliance issues by the custodian. We did not realize ther was a problem until the 1099-R was received at year end.
I have 2 questions.I ahve read in PLR2005-03036that the penalties for busting the 72t can be avoided if the payment was requested on a timely basis but the IRA provider did not get it done. Does anyone know if this would apply in this case?
Second, does anyone have any ideas on how to present this on the 2007 tax return?
Thank you for any help.
2008-03-20 08:13, By: Ron, IP: []

L2: Change of custodian- busted 72THello Ron:
Conceptually I agree that your facts & circumstances are very similar to those disclosed in PLR 2005-02036. However, in your case, sucess will be in the details. At a minimum, I would recommend:
1. You immediately make the make-up distribution and document it as such.
2. Hire professional help to correctly prepare your 2007 income tax return including disclosures and alerts to your return.
2008-03-20 16:35, By: TheBadger, IP: []