Hi all. I have a client who closed a Roth IRA in 2021. She received a 1099-R with the code J, Box 1 $10,538, Box 2a $3,138 (taxable amount). The taxpayer is 63 years old, but has only had this particular Roth IRA for 3 years, which is why the code J. However, she has had other Roth IRA's before, well before 2017, although those Roths have been totally distributed  in previous years and as of 12/31/21 she does not have any open Roth's. My understanding is that as long as she had any Roth prior to 2017, she should not be subject to the penalty or any tax on the earnings, even though this particualr Roth does not meet the 5 year requirement. Am I misunderstanding that rule, or should she not have to pay tax/penalty on the earnings?

Thanks in advance for your help.