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As of December 31, 2010 you had excess accumulations in your IRA due to the lack of distributions. There is a penalty tax 50% of the excess accumulation amount. The penalty is calculated on page 2 of Form 5329 (link below). You can request a waiver of tax if you can justify the failure was due to a reasonable error. See page 6 of Form 5329 instructions, second link below.