Since it is a 2020 tax return she can check off the box for corona virus and spread out over 3 years if certain circumstances  exist. First did the distribution have anything to do with the pandimic. If this was case where she was drawing it out ayway then the answer is no. Many individuals in the trades had the opportunity to take large amount of money out of their 401 k without any early withdrawl penalty and spread it out over 3 years. Does your client fall into this catergory. If not there is no way legally they can claim corona virus and will have to pay taxes on the whole amount and since it is code 1 they have a 10percent withdrawl penalty. There are some other concerns regarding 2021 but get thru 2020 first.