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That would depend on what you mean by "withdrawing too much". If you mean that you withdraw so much during the plan period (the longer of 5 years or until you reach age 59 1/2) that you run out of funds then the answer is no. According to the IRS website:

"If an individual's assets in an individual account plan or an IRA are depleted, the individual will not be subject to the income tax of section 72(t)(1) of the Code as a result of not receiving substantially equal periodic payments. In addition, the recapture tax described in section 72(t)(4) of the Code will not be applicable." If you mean that you withdraw more than allowed (using one of the 3 approved withdrawl methods: Minimum Distribution, Fixed Amortization or Fixed Annuitization) under the 72(t) rule then yes you will be subject to the 10% penalty and may be subject to the recapture tax specified in 72(t)(4).

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