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Yes, the 72T rues are applies to see whether or a not distributions from the IRA are subject to the penalty....
If the second IRA is truly a separate account, the THAT IRA will have the same guidelines, tests, based on when the SEP payments were started from THAT IRA
See this from Ed Slott, one of the premier IRA experts in the country:
Yes, that is correct. You can select only one IRA for the 72t plan, but you cannot use only part of the balance any IRA accounts you select. Therefore, before the plan is started a reverse calculator should be used to determine the account balance needed to produce the annual distribution needed. The max interest rate should be used and an individual (not joint) calculation done. Various direct transfers between IRA account should then be done to create an IRA account that holds the balance indicated by the reverse calculator. The other IRA accounts not part of the 72t plan can be used for emergency needs or be used to start a second independent 72t plan later on if living costs increase. Each plan is totally independent of the other.
I underlind the pertinent sections
hope this helps
(let me know if you have any questions at all
Very hard to understand you. Can you just say yes or no. Thank you.