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The only way to make the amortization or annuity methods "less risky" is to get an IRS private letter ruling allowing annual recalculation, or to go ahead and do the recalculation without the benefit of your own PLR and accept the small chance that the IRS will object and assess the 10% penalty.

Intercst, the above is no longer true. The IRS has issued internal memorandum (which is discoverable and establishes precedent) which describe in reasonable detail how & when the IRS considers use of the amortization or annuity methods in conjunction with annual recalculation to be acceptable. See my post #10834 on the REHP.

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