Here is our situation. John died 7/30/18 at age 80 and did not take his MRD for 2018. The beneficiary of his IRA was the John Irrevocable Trust (Rev trust that became revocable at his death). The IRA custodian was unable to get the MRD for 2018 to the trustee until 1/10/19. We feel the trustee has reasonable cause to request waiver of penalty. The Trust is under a Section 645 election for a 6/30/19 YE due 10/15/19.
The Form 5329 is only an attachment to a Form 1040, not a 1041. Has anyone run into this situation before? I am thinking of preparing the 5329 with a full explanation and efiling it with the 2018 1040. Then I will save the Form 5329 and attach it as a PDF to the efiled return for the 6/30/19 1041. Does anyone have any other ideas, or had this issue before?
Thanks