Lisa -

My understanding is, if you are a "qualified individual" (at any time of the year) which my client is, then ANY distributions taken from 1/1/20 through 12/31/20 are treated as corona related distributions.

My client was taking periodic IRA distributions from January to September of $5K/month ($45K).

In October he became a "qualified individual". Needed $50K more. Took it and did not take any more distributions.

1099-R shows full $95K. However, he only wants to defer the $50K over 3 years.

I am beginning to think it is an "all or nothing" deal.