Go to Form 5329, right after Line 1 there is a list of things that will waive the 10% penalty, scroll down and Look for Distributions Not subject to additional Tax, find Letter L, write the amount of the distribution and you will see that the software will write code 12 on Line 2 and waive the penaltly. There will be another way to do it once the software updates the 1099R on February 18. Hope it helps. If you look at the instructions of Form 5329, in the IRS website, Code 12 includes the Coronavirus Related Distribtuions Waiver. Thank you."

From the Form 5329 instructions:

You received a distribution subject to the tax on early distributions from a qualified retirement plan (other than a Roth IRA) and you meet an exception to the tax on early distributions from the list shown later, but box 7 of your Form 1099-R doesn’t indicate an exception or the exception doesn’t apply to the entire distribution."

And there are people asking on this forum about a client's distribution where there was withholding, and then they did a rollover. However, it seems they needed to see the explanation for the math to understand gross vs net for rollover contributions. You cannot ask for the withholding to be returned, so that part does not qualify; or, they didn't put it back timely.

"Any taxable amount not rolled over must be included in income and may be subject to the 10% additional tax on early distributions."

There are many reasons you might need to use 5329, which is for the penalty. It can even be filed without a 1040.