If the amount distributed during the taxable year of the payee under any qualified retirement plan or any eligible deferred compensation plan (as defined in ) is less than the minimum required distribution for such taxable year, there is hereby imposed a tax equal to 25 percent of the amount by which such minimum required distribution exceeds the actual amount distributed during the taxable year. The tax imposed by this section shall be paid by the payee.
For purposes of this section, the term “minimum required distribution” means the minimum amount required to be distributed during a taxable year under , 403(b)(10), 408(a)(6), 408(b)(3), or 457(d)(2), as the case may be, as determined under regulations prescribed by the Secretary.
(1) a plan described in which includes a trust exempt from tax under ,
(2) an annuity plan described in ,
(3) an annuity contract described in ,
(4) an individual retirement account described in , or
(5) an individual retirement annuity described in .
(1) the shortfall described in subsection (a) in the amount distributed during any taxable year was due to reasonable error, and
(2) reasonable steps are being taken to remedy the shortfall,
(1) Reduction
In the case of a taxpayer who—
(A) receives a distribution, during the correction window, of the amount which resulted in imposition of a tax under subsection (a) from the same plan to which such tax relates, and
(B) submits a return, during the correction window, reflecting such tax (as modified by this subsection),
the first sentence of subsection (a) shall be applied by substituting “10 percent” for “25 percent”.
(2) Correction window
For purposes of this subsection, the term “correction window” means the period of time beginning on the date on which the tax under subsection (a) is imposed with respect to a shortfall of distributions from a plan described in subsection (a), and ending on the earliest of—
(A) the date of mailing a notice of deficiency with respect to the tax imposed by subsection (a) under section 6212,
(B) the date on which the tax imposed by subsection (a) is assessed, or
(C) the last day of the second taxable year that begins after the end of the taxable year in which the tax under subsection (a) is imposed.