Badger gave good advice on splitting the IRA into 2 IRAs. Use one to make the payments and one for future "just in case" emergency penalty withdrawals. Then if the emergency happens, the SEPP payments from IRA #1 won't be subject to back dated penalties.For IRA #1, if you use the annuity method; use within 80% - 120% of the US Treasury rate as the implied interest rate. PLRs indicate imply that the IRS feels this is the "reasonable rate" stated in Pub 590.*Cat
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