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<<I'm making 72t withdrawals. I'm supposed to continue this until I'm 59 1/2. Won't this exclude me from making a full rollover to the Roth IRA, since that would end my 72t withdrawals. Would that make my 1997 withdrawal subject to a 10% penalty for early withdrawals.

Also if a rollover is allowed, I assume that would be added to my taxable income and take me out of my current tax bracket.>>

Remember that if you roll over to a Roth IRA, you'll pay the tax NOW (or at least over 4 years), and should be able to avoid the penalty. The 5 year minimum rule was established so that you couldn't make an early election (say at age 57), and then switch to a greater distribution prior to age 59 1/2.

The Roth IRA rollover provisions say that as long as you otherwise qualify, you would be able to make the rollover to a Roth IRA if the distribution meets the requirements for a qualified rollover contribution under Code Section 408(d)(3). It would seem that your IRA would qualify for the Roth rollover, even though you have been taking prior minimum distributions.

And yes, since the rollover amount will be added to your income, you may be pushed up into a higher tax bracket (depending upon the size of the rollover). So you really have to do some planning before you make your decision.

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