Proposed SEPP Plan Questions

L1: Proposed SEPP Plan QuestionsI have the following questions regarding my proposed SEPP Plan:
1. I plan to commence my SEPP October 31st or November 1st, 2005,employing themonthlydistribution method. Is there a requirement that monthly distribritions from my costodian be on the first or last day of each month?
2.I plan is to use my recorded IRA account balance of September 30th, 2005. Does this fall within the guidelines of 72t, IRS Pub. 590-2002 or do I have to use Dec. 31st, 2004 (prior year)?
3. My plan is to use the Annual Recalulation SEPP method and employ the ammorization method. Is it within 72t guidelines forme to perform the annualrecalculation on January 1 or January 31, 2006 as well as each subsequent year or doI have torecalculateon the specific date of October 31st or November 1st in which the SEPP plan began distributions in 2005?
4. Inemploying theAnnual Recalculation method, is it required that the account balance date of December 31st of the prioryear be used or isit acceptable to use any givenaccount balance date of the prior year?
5.With IRS Pub.590 scheduled for releaseon 11/22/05, are there any potential major changes/impacts that could effectmySEPP Plan which shall be implementedonOctober 31st or November 1st, 2005?
The following is my SEPP Documentation Plan:
1. I am documenting theSEPP Distrubition Plan using the leased software provided bythe 72.net sitewith hard copies reviewed and retained by my CPA and Costodian/Financial Advisor.
2. ASEPP monthly distribution log has been developed to track transfers from IRAAccountto my taxable account with my Costodian. Additionally, I plan to maintain a copy each monthly IRA and taxable account statement provided by my Costodian.
3. I have made a hard copy of PLR 200432021 , dated May 11th, 2004 which approved theuse of the annual recalculation and ammortizationmethods inimplementing SEPP’s under the 72t guidelines.
Are there any SEPP Documentationissues/guidelines whichI may have missed?
Regards,
Dave2005-10-24 12:42, By: dave, IP: [24.113.72.62]

L2: Proposed SEPP Plan QuestionsSection #1

No.
Should be Ok.
I would use a January date.
I would use the December 31st (or year end date).
No changes that I am aware of.
Section #2

As long as the assumptions are correct, you should end up with the right numbers.
Great planning.
Nice but probably un-necessary as it is a matter of public record.
It sounds like you are off to a great start and have planned for the real key in a successfull SEPP. Good planning, good documemtation and a relationship with your tax professional!
2005-10-24 12:55, By: Gfw, IP: [172.16.1.71]