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Yes. Otherwise, to get access to one's traditional IRA while still under 59.5 and avoid the 10% penalty, they'd only need to convert to a Roth and then withdraw....with no AGI limit now on Roth conversions, the 10% early withdrawal penalty on traditional IRAs would be moot.

Note also that unlike a qualified withdrawal, where there is no penalty and no tax on withdrawals if a person attains age 59.5 and has held a Roth at least 5 years, whichever comes LATER. The rule on avoiding the 10% penalty on Roth coversion withdrawals is having held the conversion 5 years or attaining age 59.5, whichever comes SOONER.

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