deferral period

(4) Change in substantially equal payments (A) In general If— (i) paragraph (1) does not apply to a distribution by reason of paragraph (2)(A)(iv), and (ii) the series of payments under such paragraph are subsequently modified (other than by reason of death or disability or a distribution to which paragraph (10) applies)— (I) before the close of the 5-year period beginning with the date of the first payment and after the employee attains age 59½, or (II) before the employee attains age 59½, the taxpayer’s tax for the 1st taxable year in which such modification occurs shall be increased by an amount, determined under regulations, equal to the tax which (but for paragraph (2)(A)(iv)) would have been imposed, plus interest for the deferral period. (B) Deferral period For purposes of this paragraph, the term “deferral period” means the period beginning with the taxable year in which (without regard to paragraph (2)(A)(iv)) the distribution would have been includible in gross income and ending with the taxable year in which the modification described in subparagraph (A) occurs.


26 USC § 72(t)()(4)

Scoping language

For purposes of this paragraph
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