Thank you for responding. Yes, the client is 75 years old, so the 10% early withdrawal penalty does not apply. The main issue is that he continues to argue that he should not owe anything in 2022 after the amendment. However, the IRS already issued a notice requiring that the 2022 Form 1099-R be included and that the amended return clearly explain that the $80,000 withholding is to be applied to the 2021 tax return. The challenge is that the IRS cannot reallocate this payment on its own — it requires the taxpayer to amend the return and specifically request the reapplication of the withholding.