Again, there is a 20% mandatory withholding from accounts under employer plans. Not under Trad IRA; that is only 10%. You mentioned 20% mandatory withholding. What is the account type as marked on the 1099-R? What is the taxpayer's account type?

From: https://www.irs.gov/retirement-plans/plan-participant-employee/rollovers-of-retirement-plan-and-ira-...

"Will taxes be withheld from my distribution?

• IRAs: An IRA distribution paid to you is subject to 10% withholding unless you elect out of withholding or choose to have a different amount withheld. You can avoid withholding taxes if you choose to do a trustee-to-trustee transfer to another IRA.
   
• Retirement plans: A retirement plan distribution paid to you is subject to mandatory withholding of 20%, even if you intend to roll it over later. Withholding does not apply if you roll over the amount directly to another retirement plan or to an IRA. A distribution sent to you in the form of a check payable to the receiving plan or IRA is not subject to withholding."

Code 2 is an Early Distribution code, where an exception might apply:

https://www.irs.gov/retirement-plans/plan-participant-employee/retirement-topics-exceptions-to-tax-o...

Your taxpayer has a split activity. Do you know of an exception for each partial amount? Or, at least one of the amounts is subject to penalty?