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However, the case never seems to address the specific limitations in 72t(4) to death and disability, which the court has effectively dismantled by this ruling.
I had thought that the references to the earlier exceptions were meant to establish a specific order for applying multiple exceptions. For example, the first home exception would be one of the last applied and that would prevent erosion of the 10,000 limit. Medical expenses would be one of the last in order to prevent the 7.5% floor from limiting the total exceptions that may apply.
I would think the IRS would appeal this since it opens a few more cans of worms, and I can see it causing an expansion of the problems already caused by all the 5329 forms. 
If this case holds there are still more questions, eg will a SEPP participant be able to add all the other exceptions to the annual SEPP distribution, or can they just add some of them, or part of one of them?

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