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{{A better approach, again IMHO, would be to split off a chunk of your IRA to separate accounts. Then you can pick and choose which to use for SEPP and which to use for education. That way there would be no room for an IRS challenge.}}
{{Let me get this straight: My IRA is a pie. The IRS may not want me to have two pieces of pie. But if I first cut the pie in half I can have two identical size pieces from the respective halves and that is OK? Can you provide any insight into the IRS's logic here?}}

It's the same logic that says a bank will only insure $100,000 of your account, but if you have a second account, it will insure another $100,000. It's the same logic that says a credit card company will only give you a $15,000 credit line on your credit card, but you can get another credit card if you want. It's the same logic that says I pay a "school tax" even though I don't have any kids, and don't use the schools. It's the same kind of "wash sale" logic that says I can buy back a stock after 31 days, but not 30, and keep the loss for tax purposes.

There are rules. They exist to simplify record keeping, and to make sure that the objectives of the various and several programs are accomplished within the guidelines of the rules set up for those programs. In this case they may not want you co-mingling funds for your own IRA and for educational purposes in a SEPP and deciding later which was what.

Get over it, and get on with it.
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